ML18096A817

Requests Corrections to SER and Approval Ltr Dtd 890720 That Granted Util Exemptions from Requirements of 10CFR50 App R. Typographical Errors & Inconsistant Info Provide Basis for Request

ML18096A817
Person / Time
Site:	Salem
Issue date:	07/14/1992
From:	Labruna S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N92092, NUDOCS 9207160059
Download: ML18096A817 (11)

Text

Public Service Electric and Gas Company Stanley LaBruna Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 Vice President - Nuclear Operations JUL 14 1992 NLR-N92092 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Gentlemen:

CORRECTION OF SAFETY EVALUATION REPORT APPENDIX R EXEMPTIONS SALEM GENERATING STATION, UNIT NOS. .1 AND 2

.DOCKET NOS. 50-272 .AND 50-311 This letter reqrie~ts* corrections to the_ Safety Evaluation Report (SER) and. to the Approval Letter_, dated July 20, 1989, that granted, to Salem Generating Station, several exemptions from the

• requirements of 10CFR50 Appendix R.

• Since receipt of the exemption apprc;>val-, PSE&G has determined that there are some significant typographical errors. Additionally, several of the discussions in the SER and in the Approval Letter, which provide the background and basis.for exemption approval, contain *information that.is inconsistent with the *corresponding information.contained in our June 15, 1988 exemption request.

PSE&G believes that sound technical bases for these exemptions were provided in our submittal, and that the inconsistencies that' we have identified do not adversely affect the conclusions in the SER. However, we want to ensure a proper understanding of each exemption approval basis.

Attachment 1 includes descriptions of the exemptions for which the SER contains technical discrepancies and Attachment 2 provides a listing of typographical errors and minor clarifications.

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Document Control Desk JUL 14 1992 NLR-N92092 If you have any questions regarding this request, we will be pleased to discuss them with you.

Sincerely, c Mr. T. T. Martin, Administrator USNRC Region I Mr. J. c. Stone USNRC Licensing Project Manager Mr. T. P. Johnson USNRC Senior Resident Inspector Mr. K. Tosch, Chief, Bureau of Nuclear Engineering New Jersey Department of Environmental Protection

JUL 1 4 1992

.. Document Control Deskfl

~-N92092 ATmCHMENl' 1 TEXlINICAL DISCREPANCIES

GENERIC aAcrroN - APPLICABILITY OF ~ SUHIT'ITAIS The NRC, in a letter dated July 20, 1989, granted certain exemptions from the requirements of 10 CFR 50, Appendix R as requested and justified in PSE&G' s Revised Exemption Requests submittal dated July 15, 1988. Page 1-1 of the NRC's supporting Safety Evaluation Report references that "The July 15, 1988 submittal supplements and amends information contained in previous letters to the staff including those letters dated Januacy 31, 1985 and Januacy 17, 1986." In fact, PSE&G's transmittal cover letter dated July 15, 1988 states, "The attached requests represent a corrplete package and replace the previous submittals in their entirety. "

The approach of replacing previous submittals in their entirety was taken to avoid future confusion in that the technical position developed for several fire areas shifted over the years due to evolving interpretations and more effective solutions. Therefore, not all information previously submitted is still applicable. It should also be noted that, relative to Appendix R interpretations provided, this approach is consistent with that taken in Generic letter 86-10 which states, "To the extent that this guidance may be inconsistent with prior guidance (including Generic letter 83-33), it is intended that the current letter takes precedence."

It remains PSE&G's position that the requests attached to our July 15, 1988 submittal represent a complete package and replace our previous submittals in their entirety. Therefore, the NRC justification for granting the requested exemptions should not reference the earlier PSE&G exemption requests to the extent that information in those requests may be inconsistent with our current submittal.

This issue is also reflected on page 2 of the Approval letter.

e e CORRECTION 'IO EXEMPI'ION NO. 2 1 CONTROL ROOM CDMPLEX (CONTROL ROOM IXX>RS AND VENTIIATION)

Exemption No. 2 for fire area 12FA-AB-122A, Control Room Complex, as submitted to the NRC in PSE&G 1 s July 15, 1988 Revised Exerrption Requests (RER) is a request for exemption from the requirements of 10CFR50 Appendix R, Section III.G.3 to the extent that it requires a fixed fire suppression system for an area where alternate shutdown capability is provided. The exemption approval, dated July 20, 1989, contains a description of the Control Room Complex that was not provided in our RER.

Specifically, page 6, section 2.2 of the Approval letter and page 3-1 of the SER contain the following statements, "Although the walls separating the control rooms are not fire walls, the doors leading to the control rooms are rated for 3/4 hour. The doors are marked as fire doors and must remain closed. They are also equipped with automatic door closures. The doors have been included in the fire door list and are governed as a Technical Specification item. The restrictions on these doors are designed to prevent the propagation of smoke from one control room to the other .... The ventilation systems for both units have been balanced to maintain equal pressure in both control rooms. Tests have been perfonned and it has been confinned that smoke does not propagate between control rooms when the ventilation systems are balanced. The damper vanes are mechanically locked in position to maintain the pressure balance. 11 PSE&G 1 s Exemption Request No. 2, dated July 15, 1988, describes the physical configuration of the control room complex as follows: "The rooms within this area are separated by hollow core metal office partitions except the Air Conditioning Rooms, which are separated by a reinforced concrete wall. The two Control Rooms are separated by a 10 1 wide corridor. Room partitions between the Control Rooms and the Senior Shift and Shift SUpervisor 1 s office contain glass panels. The Control Rooms are separated from their associated control Equipment Rooms by built-in steel frame control cabinets. Dropped ceilings are finished with ac6ustic tile."

Neither the identification of 3/4 hour rated fire doors nor the arrangement of the ventilation system was included in PSE&G 1 s submittal.

The infonnation referred to in the NRR approval correspondence was material included in a previously submitted request for exemption from the requirements of 10CFR50 Appendix R, Section III.G.3 to the extent that there is no fixed fire suppression in the Control Room Complex, and from Section III.G.2.a to the extent that the Unit 1 and Unit 2 control rooms are not separated by a 3-hour rated fire barrier as submitted in letter dated Januru:y 17, 1986. The issue associated with the requirements of Section III.G.2.a focused on the personnel requirements necessru:y for simultaneously perfo:rming alternate shutdown actions for both units. Technical justification provided for these two exemptions was developed considering the combined effects of both exemptions rather than looking at each request individually. The overriding consideration of the combined effects was the need to avoid siinultaneously evacuating both control rooms and perfonning alternate shutdown actions on both units due to personnel limitations. Although not specifically stated, various provisions included in the technical justification were associated with either lack of a fixed fire suppression system or lack of a 3-hour rated fire barrier, not necessarily both issues.

e Correction to Exenption No. 2 - Continued

-* (Cc;>nt;rol Roam Doors and Ventilation)

Recognizing that technical justification for lack of a fixed fire suppression system focuses on the ability for early warning detection of a fire provided by the addition of smoke detectors throughout the area and quick response to a fire due to the constant manning of the control roams, it can be concluded that the fire, itself, would not be cause to evacuate both control roams simultaneously. Without physical separation between the control roams, the potential for propagation of smoke resulting from the fire could be cause for simultaneous control room evacuation. '!he provisions that included the identification of 3/4 hour fire rated doors leading to the control roams and the discussion that the doors are equipped with automatic door closures, would remain closed, and would be governed as a Technical Specification item along with the description of the ventilation systems were intended to support the position that a fire in one control room would not force the evacuation of the other control room due to uncontrolled smoke propagation. Therefore, these provisions were specifically associated with the request for exemption from the requirements of 10CFR50 Appendix R, Section III.G.2.a to the extent that the Uni:t 1 and Unit 2 control rooms are not separated by a 3-hour rated fire barrier. SUbsequently, via letter dated August 29, 1986, PSE&G withdrew the request for exemption from the requirements of Section III.G.2.a for lack of a 3-hour fire rated barrier between the control roams. As such, those provisions contained in the technical justification that were specific to this exemption request were no longer necessacy. In PSE&G' s letter dated July 15, 1988, all of the exemption requests were corrpiled and resubmitted for clarity and ease of review. Indication was provided in Exemption No. 2 for the control room corrplex (with regard to the basis for our withdrawal of the exemption request) that adequate personnel are available to perfonn simultaneous alternate shutdown of both units. Specific provisions previously included in the technical justification pertaining to this condition, including the identification of the 3/4 hour rated fire doors and discussion of the ventilation system, were removed. The resubmitted exemption request focuses on the fire area as a whole, with no provision for subdivision for separating the control rooms.

It is PSE&G's position that while maintaining the doors between the control roams closed plays a role in the overall effectiveness of the ventilation systems for the control rooms and represents a good practice to fire protection, as identified in Exemption No. 2, their necessity as fire rated components is no longer relevant and the imposition of Technical Specification provisions against the doors is not necessacy. In addition, physical design constraints placed on the ventilation system when considering possible future design changes solely for fire protection purposes are no longer necessary.

Finally, it should be noted that smoke propagation alone is not considered to be cause for immediate evacuation of control roams. Based on the requirements of Branch Technical Position APCSB 9.5-1 Appendix A, self-contained breathing apparatus has been provided for control room personnel.

CORRECTION' EXEMPI'ION NO. 5, MECHANICAL (PARI'IAL AREA DEI'ECTION)

~ON AREAS Exemption No. 5 for fire areas 1 & 2FA-MP-78I, Mechanical Penetration Areas as submitted in our July 15, 1988, Revised Exemption Requests (RER) is a request for exemption from the requirements of 10CFR50 Appendix R, Section III.G.2 to the extent that it requires separation of redundant cables and equipment by 1-hour rated fire barriers plus automatic suppression and area-wide detection.

Specifically, fire areas 1 & 2FA-MP-78I are not protected by automatic suppression systems and area-wide detection capability.

Relative to area-wide detection, Enclosure 1, page 13 of PSE&G's July 15, 1988 submittal states, "Partial area detection is installed for the protection of the major fire hazards on Elevation 78' and 100' * " In addition, Enclosure 1, page 14 declares, "'!he electrical cables are widely dispersed and protected by the partial detection system." Finally, as stated in the conclusion for Exemption No. 5, 11 * *

• the installation of area-wide detection *** in the area would not significantly enhance the level of fire protection for safe shutdown cabling. II However, the NRC's letter dated July 20, 1989, which granted the exemptions from the requirements of 10CFR50 Appendix R, indicates, in Section 4 .1, page 11, that an exemption was requested from section III.G.2.c to the extent that it requires an automatic fire suppression system installed in a fire area that contains redundant safe shutdown equipment. '!here is no mention made of our description of partial area detection. SUbsequently, section 4.2, states,

"'!he existing fire protection includes an area-wide fire detection system *** ";

and in Section 4.3 it states that, "An area-wide detection system is available in this area and in adjacent areas."

This information is inconsistent with PSE&G's July 15, 1988 submittal as noted above. In addition, the info:nnation introduced, dealing with the detection provided in adjacent fire areas, was neither provided with Exemption No. 12 nor is it consistent with the configuration of adjacent areas as described in our Exemption No. 4 for fire areas 1 & 2FA-EP-lOOG and for 1 & 2FA PP-lOOH to the east, and Exemption No's. 3 and 7 for fire areas 1 & 2FA-AB-100C and 1 &

2FA-AB-84B, respectively, to the north (south for Unit 2).

For those other fire areas for which an exemption for partial area detection was requested, the position established by the July 20, 1989 NRC letter is that an exemption is not required. For example, section 3.3 states, "'!he absence of area-wide detection systems is not considered a non-conformance.

Generic Letter 86-10 stipulates that '\Nhere partial coverage automatic fire detection and suppression exist in an area, licensees may perfonn a fire hazards evaluation to justify the lack of complete coverage. '!he staff considers the summai:y analysis contained in the exemption requests as being sufficient to satisfy the guidelines issued in the Generic Letter." rater, Section 3.5 states, "'!he licensee's request for an exemption pertaining to the lack of area-wide automatic fire detection in these areas is not needed."

'Iherefore, there appears to be an inconsistency in the NRC evaluation of this fire area relative to the treabnent of other fire areas with partial area detection and with the current info:nnation submitted by PSE&G. PSE&G maintains that installation of area-wide detection would not significantly enhance the present level of fire protection for safe shutdown cabling.

e e OORRECI'ION 'ID EXEMPI'ION NO. 5 I MECEANICAL PENEI'RATION ARFAS (FIRE !DAD)

Exemption No. 5 for fire areas 1 & 2FA-MP-78I, Mechanical Penetration Areas as submitted in our July 15, 1988, Revised Exemption Requests (RER) is a request for exemption from the requirements of 10CFR50 Appendix R, Section III.G.2 to the extent that it requires separation of redundant cables and equipment by 1-hour rated fire barriers plus automatic suppression and area-wide detection.

Specifically, fire areas 1 & 2FA-MP-78I are not protected by automatic suppression systems and area-wide detection capability.

'!he discussion relative to this fire area provided in Section 4.2 of the SER dated July 20, 1989 states, "The fire load in this area is low (less than 10,000 Btu per square foot) and there are no fire hazardous equipment or concentrated heavy fire loads in the area. The low fire loads of 10,000 Btu per square foot translates into a fire severity of less than 10 minutes ... ".

A similar reference to a fire load of less than 10,000 Btu per square foot is made later, in Section 4. 3, as well.

This infonnation is contrary to the PSE&G July 15, 1988 submittal (Enclosure 1, Page 13), which describes the fire load in this area, stating, "The in-situ combustibles in the Mechanical Peneption Area will result in a total fire load of approximately 28, 000 Btu/ft (21 minutes) . " Additionally, described on page 14, " *** major combustibles in the area consist of charcoal filters and electrical cable insulation. The charcoal filters are protected by automatic deluge suppression systems. The electric cables are widely dispersed ... "

It is PSE&G's position that the infonnation presented in the SER, dated July 20, 1989, incorrectly reflects the plant conditions as described in our 1988 exemption request. However, it is not considered that this discrepancy would ilrpact the approval of the exemption for lack of automatic suppression and area wide detection as requested by PSE&G. When considering the type of combustible material representing the majority of the fire load (cable insulation), it would be anticipated that, if a fire were to start, it would be slow buntlng and develop smoke in its incipient stage. '!he smoke would be detected by the partial area detection system, pennitting the Fire Brigade to be smmnoned. Recogni~ing the nature of ~s type of fire, the difference between 10,000 Btu/ft and 28,000 Btu/ft is considered to be insignificant.

In addition, as noted in PSE&G's July 15, 1988 letter, 1-hour fire barriers were proposed (and have been, subsequently, installed) that maintain one division of cable needed for safe shutdown free of fire damage until the Fire Brigade extinguishes the fire.

CDRRECI'ION 'IO EXEMPI'ION NOS. 7 & 9, 460V & 4160V SWITCHGFAR ROCNS (MANUAL CD2 SUPPRF.sSION SYSTEM)

Exemption No. 7, granted for fire areas 1 & 2 FA-AB-84A, 460V switchgear Room, in the NRC letter dated July 20, 1989, credits the use of "a manually actuated fire suppression system in lieu of an automatic system in the 460V switchgear Room." Exemption No. 9, granted for fire areas 1 & 2 FA-AB-64A, 4160V switchgear Room, as stated on page 26 of the SER, does not include this provision. It should. '!he description by NRC in Section 5.1, states, "In addition, the fire suppression system in the 4160V switchgear room is manually actuated." In Section 5.3 it states, "Also, the 4160V switchgear room is protected by a manually actuated fire suppression system. '!he. staff issued an exemption for the lack of an automatic fire suppression system in the 4160V switchgear room by letter dated June 17, 1983. 11 Finally, in Section 5.4 it is stated, "'!he staff's evaluation of the June 17, 1983 exemption request for the lack of an automatic fire suppression system in the 4160V switchgear room remains valid. II The above discussions are also consistent with the info:nnation provided in Exemption No. 9 4160V switchgear Room as submitted in PSE&G's July 15, 1988, Revised Exemption Requests. Also included in that submittal, and described in Exemption No. 6, 460V switchgear Room, "The existing manual cartx>n dioxide suppression system in this area will be changed to an automatic suppression system."

Based on the info:nnation provided in PSE&G's July 15, 1988 letter, and in Section 5 of NRR's July 20, 1989 SER, it is PSE&G's position that the exemption granted for use of a manual CD2 system in lieu of an automatic system is associated with fire areas 1 & 2 FA-AB-64A (NRR Exemption No. 9) rather than fire areas 1 & 2 FA-AB-84A (NRR Exemption No. 7).

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Attachment 2

1. Section 2, page 2 and throughout - "Fire Areas 1 and 2 FA-AB-122A should read "Fire Area 12 FA-AB-122A" (also see page 5-1 and throughout the SER) *

2. section 3. 2, page 9 - "Fire Areas 1 and 2 FA-EP-1006 should read "Fire Areas 1 and 2 FA-EP-lOOG" (also see page 5-1 and throughout the SER) *

3. Section 4, page 11 and throughout - "Fire Areas 1 and 2 FA-MP-781" should be "* ** FA-MP-78.I (also see page 4-1 and throughout the SER).

4* section 4 I page 11 - References to the safety Injection system correspond to the Olarging System (high head) listed on page 14 of Enclosure 1 of the July 15, 1988, Revised Exemption Requests (also see section No. 4 of the SER).

5. section 6, page 15 - References to the Chemical and Volume Control System (CVCS) correspond to the Charging System discussed on page 20 of Enclosure 1 of the July 15, 1988, Revised Exemption Requests (also see section No. 7 of the SER) *

6. Section 8.4, page 22 - "Panel 35 11 should be "Panel 335 11 (also see page 9-2 of the SER) *

7. SUmmary No. 11, page 27 - Lists the exemption as only applicable to Fire Areas 1 and 2 FA-AB-45A. '!his exemption also applies to Fire Areas 1 and 2 FA-AB-45B.