ML20236S289

Exemption from Requirements of 10CFR50,App R,Section III.G.2 Re Fire Protection of Safe Shutdown Cables & Equipment Located Inside Containment Bldg

ML20236S289
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	11/12/1987
From:	Crutchfield D Office of Nuclear Reactor Regulation
To:	PORTLAND GENERAL ELECTRIC CO.
Shared Package
ML20236S290	List: ML20236S289 ML20236S399 ML20236S402
References
NUDOCS 8711250031
Download: ML20236S289 (8)

Text

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., %g% .;%26.1.r :y; ENCLOSURE 1- 1 i

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of- Docket No. 50-344 PORTLAND GENERAL ELECTRIC COMPANY, et. al.

TROJAN NUCLEAR PLANT EXEMPTION I.

The Portland General Electric Company (PGE, the Licensee) is the holder of Operating License No. NPF-1 which authorizes operation of the Trojan Nuclear Plant. The license provides, among other things, that the Trojan Nuclear Plant is subject to all rules, regulations, and Orders of the Commission now or hereafter in effect.

i The plant..is a pressurized water reactor at the Licensee's site located  !

j in Prescott, Oregon.

II, 4 i

On November 19, 1980, the Commission published a revised Section 50.48 and a new Appendix R to 10 CFR 50 regarding fire protection features of nuclear power plants. The revised Section 50.48 and Appendix R became effec-tive on February 17, 1981.Section III of Appendix R contains 15 subsections, lettered A through 0, each of which specified requirements for a particular aspect of the fire protection features at a nuclear power plant. One of these subsections, III.G. is the subject of the Licensee's exemption requests.

Subsection III.G.2 of Appendix R requires that one train of cables and equipmentnecessarytoachieveandmaintainsafeshutdownbemaintainedfre.eM of fire damage by one of the following means: ,

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L l- a. Separation of cables and equipment and associated nonsafety circuits 1

of redundant trains by a fire barrier having a 3-hour rating.

Structural steel forming a part of or supporting such fire barriers shall be protected to provide fire resistance equivalent to that required of the barrier.

b. Separation of cables and equipment and associated nonsafety circuits of 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 suppression system shall be installed in the fire area.

c. Enclosure of cable and equipment and associated nonsafety circuits of one redundant train in a fire barrier having a 1-hour rating. In addition, fire detectors and an automatic fire suppression system l

shall be installed in the fire area.

Subsection III.G.3 of Appendix R requires that for areas, rooms, or zones 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 letters dated May 5 and August 21, 1981, and March 29, July 17, and September 21, 1982, the Licensee requested exemptions from specific i

requirements of Appendix R. In December 1982, the NRC issued a Safety Evaluation Report granting six of the seven exemptions requested.

By letters dated April 27, June 7. June 30, July 15, and November 30, '

1983, the Licensee requested additional exemptions, which were granted by NRC l letters dated July 8, 1983 and March 15, 1984.

The NRC conducted a special site inspection of the plant from June 20 l

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through 24, 1983. The results of this inspection were transmitted by a NRC

. letter dated August 31, 1983. By letter dated November 1,1983, the NRC withdrew the previously granted exemption for the cable penetration area outside of the containment.

By letter dated July 8,1983, the Licensee described a corrective action program which responded to the NRC special inspection.. By letter dated .

September 28, 1983, the Licensee responded to the NRC letter dated August 31, 1983.

On July 30, 1984, the Licensee submitted a complete Appendix R review.

By letter dated January 24, 1985, the NRC requested additional information related to the safe shutdown review which the Licensee provided in a letter dated March 6.-1985. By letter dated February 8, 1985, the Licensee withdrew the exemption request for Fire Area R-1 (containment). By letter dated May 31, 1985, the Licensee submitted Amendment 1 to the Appendix R review.

The amendment included modifications of Fire Area E-1, structural steel analysis for the fuel and auxiliary buildings, updated data tables, and designation of a new fire area (Fire Area A-4a). The licensee requested a supplemental exemption for Fire Area T1, from the requirements of Section III.G.2.b in an October 16, 1986 letter. However, this request was subsequently withdrawn by letter dated May 8,1987 when the licensee determined that it was no longer necessary. Rather, the licensee requested staff approval of the request under the provisions of Generic Letter 86-10, Section 3.1.2.

The following list of exemption requests reflects the latest status:

1. Fuel and Auxiliary Buildings, Elevations 45, 61, and 77 Feet (Fire Area A-4).

Exemptions were requested from the specific requirements of Section Ill.G.2.a to the extent that redutidant safe shutdown cables are not separated by a 3-hour rated fire barrier.

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.2. Fuel and Auxiliary Buildings, Elevations 45, 61, and 77 Feet (Fire Area A-4).

Exemptions were requested from the specific requirements of Section III.G.2.b to the extent that redundant trains of safe shutdown cables and equipment are not separated by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards ,

and to the extent that fire detectors and an automatic fire sup-pression system are not installed throughout the fire area.

3. Fuel and Auxiliary Buildings, Elevation 45 Feet (Fire Area A-4)'.

Exemptions were requested from the specific requirements of Section Ill.G.2.c to the extent that one redundant train of safe shutdown related cables and equipment are not enclosed in a fire barrier having a I-hour rating and to the extent that fire detectors and an automatic fire suppression system are not installed throughout the fire area. t

4. Electrical Penetration Area (Fire Area E-1).  ;

Exemptions were requested from the specific requirements of Section l III,G.2.b to the extent that redundant trains of safe shutdown related cables and equipment and associated nonsafety circuits are i not separated by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards.

5. Turbine Building, General Area (Fire Area T-1). l l

Exemptions were requested from the specific requirements of Section '

Ill.G.2.b to the extent that redundant trains of cables and equip-  ;

ment and associated nonsafety circuits are not separated by a horizontal distance of more than 20 feet with no intervening

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3 i combustibles or fire hazards and to the~ extent that fire detectors -

and an automatic fire suppression ' system are not installed through-out the fire area.  ;

6. Yard Area (Fire Area Y-1). j Exemptions were requested from the specific requirements of Section III.G.2.b to the extent that cables and equipment and associated nonsafety circuits of redundant trains are not separated by a-horizontal distance of more than 20 feet with no intervening com-bustibles or fire hazards and to the extent that fire detectors and an automatic fire suppression system are not installed throughout the fire area.

The Licensee has provided alternative and/or acceptable levels of fire protection for areas containing redundant safe shutdown systems not separated from each other, except for fire protection in areas containing more than a negligible combustible load and containing safe shutdown equipment or cables consisting of fire detectors or automatic fire suppression systems, portable extinguishers, and hose stations. The staff finds that there is reasonable assurance that a fire in these areas would be promptly detected and extinguished.

Based on the review of the Licensee's analysis, the staff concluded that the exemption requested from the requirements for the installation of 3-hour fire rated barriers between redundant trains of cables in Fire Area A-4 is not required where t'n e Licensee has committed to enclose one train of cables in a 3-hour fire rated enclosure because this compilu with the technical requirements of Section III.G.2.a of Appendix R. The staff has also concluded that the I installation of 3-hour fire rated barriers between other sections of redundant trains in Fire Area A-4 would not significantly increase the level of fire protection in this area.

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! I The staff has also concluded that the separation of redundant trains by more than 20 ' feet:of horizontal distance or the enclosure of one of the trains l 1

by a 1-hour fire rated enclosure and, in some cases, the installation.of fire  !

detectors and automatic fire suppression systems in Fire Areas A-4, E-1, T-1, and Y-1 would not significantly increase the level of fire protection in these areas.

By letter dated November 17, 1986, the Licensee provided information relevant to the "special circumstances" finding required by revised 10 CFR 50.12(a) (see 50FR50764). The Licensee stated that existing and proposed fire protection features at Trojan Nuclear Plant accomplish the underlying purpose of the rule.

Implementing additional modifications to provide additional suppression systems, detection systems, and fire barriers would not enhance fire protection above that already required. The staff concludes that "special circumstances" exist for the Licensee's requested exemptions in that application of the regulation-in these-particular circumstances is not necessary to achieve the underlying purposes of Appendix R to 10 CFR 50. See 10 CFR 50.12(a)(2)(ii).

IV.

Accordingly, the Comission has determined that, pursuant to 10 CFR 50.12(a), (1) these exemptions as desc,ribed in Section III are authorized by law and will not present an undue risk to the public health and safety and are consistent with comon defense and security and (2) special circumstances are present for the exemptions in that application of the regulation in these particular circumstances is not necessary to achieve the underlying purposes of Appendix R to 10 CFR 50. Therefore, the Conrnission hereby grants the following exemptions from toe requirements of Section III.G of Appendix R to 10 CFR 50:

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1. Fuel and Auxiliary Buildings, Elevations 45, 61, and 77 Feet (Fire Area A-4) to the extent that redundant trains of safe shutdown cables and equipment are not separated by a horizontal distance of -

.l more than 20 feet with no intervening combustibles or fire hazards and.to the extent that fire detectors and an automatic fire suppression system are not installed pursuant to Section III.G.2.b.

2. Fuel and Auxiliary Buildings,-Elevation 45 Feet (Fire Area A-4) to I the extent that one redundant train of safe shutdown cables and equipment are not enclosed in a fire barrier having a 1-hour rating and to the extent that fire detectors and an automatic fire suppression system are not installed in the fire area pursuant to Section III.G.2.c.

3. Fuel and Auxiliary Buildings, Elevation 61 Feet (Fire Area A-4) to the extent that redundant safe shutdown cables are not separated by a 3-hour rated fire barrier pursuant to Section III.G.2.a.

4 Electrical Penetration Area (Fire Area E-1) to the extent that i

redundant trains of safe shutdown cables and equipment and associated nonsafety circuits are not separated by a horizontal i

distance of more than 20 feet with no intervening combustibles or fire hazards pursuant to Section III.G.2.b.

5. Turbine Building, General Area (Fire Area T-1) to the extent that redundant trains of cables and equipment and associated nonsafety circuits are not separated by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards and to the extent that fire detectors and an automatic fire suppression system are not installed throughout the fire area pursuant to Section f

l III.G.2.b.

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6. Yard Area (Fire Area Y-1) to the extent that cables and equipment and associated nonsafety circuits of redundant trains are not separated by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards and to the extent that fire detectors and an automatic fire suppression syst,em are not installed throughout the fire area pursuant to Section III.G.2.b.

Pursuant to 10 CFR 51.32, the Comission has determined that the granting of these exemptions will have no significant impact on the environment (November 4,1987, 52 FR 42382).

A copy of the Safety Evaluation Report dated November 14 1987, related to this action is available for public inspection at the Commission's Public Document Room, 1717 H Street, N.W., Washington, D.C. and at the local public document room for the Trojan Nuclear Plant located at the Portland State University Library, 731 S. W. Harrison St., Portland, Oregon 97207. A copy may be obtained upon written request addressed to the U.S. Nuclear Regulatory Commission, Washington, D.C. 20555.

This Exemption is effective upon issuance.

Dated at Bethesda, Maryland this 12th day of November,1987.

FOR THE NUCLEAR REGULATORY COMMISSION De 's C hf Id, D r Division of Reactor Pr ects - III, IV, V and Special Projects Office of Nuclear Reactor Regulation

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