ML17254A974

Forwards Summary of Revs to App R Alternative Shutdown Sys, Reflecting Current NRC Positions & Clarifying Proposed Actions by Util

ML17254A974
Person / Time
Site:	Ginna
Issue date:	10/04/1984
From:	Kober R ROCHESTER GAS & ELECTRIC CORP.
To:	Paulson W Office of Nuclear Reactor Regulation
References
NUDOCS 8410110210
Download: ML17254A974 (7)

Text

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

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NBR:8410110210,OC 8q/10/04 ii .g:Rochester ACCESSION DATE: NOTARI NO DOCKET FACIL:50 244 Robert Emmet Ginna Nuclear Planti Unit G 05000244 AUTH'.NAME" AUTHOR AFFILIATION KOBERgR,I'I, Rochester Gas 8 Electric Corp.

RECIP ~ NAME RECIPIENT AFFILIATION PAULSONgl'f ~ A ~ Operating Reactors Branch 5 SUBJECT; Forwards summary of revs to "App R Alternative'hutdown Sys~" reflecting current NRC positions L clarifying proposed actions by util.

DISTRIBUTION CODE: A006D COPIES RECEIVED!LTR 'NCL SIZE:

TITLE: OR Submittal: Fire Protection NOTES:NRR/DL/SEP icy, 05000244 OL: 09/19/69 REC IP IENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL NRR ORB5 BC 01 3 3 INTERNAL; ADM/LFMB 1=- 0 ELD/HDSP IE FILE 06 1 1 IE/NHITNEYg L NRR FIORAVANT07 2 2 NRR NAMBACH NRR/D. B 09 2 2 NRR/DL DIR FI E OQ 1 1 RGN1 EXTERNAL: ACRS 11 3 3 LPDR 03 NRC PDR 02 1 1 NSIC 05 NTIS 1 1 NOTES:

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ROCHESTER GAS AND ELECTRIC CORPORATION o 89 EAST AVENUE, ROCHESTER, N.Y. 14649 0001 ROGER W. KOSER VICE PRES)OENT TELEPHONE ELECTRIC 6 STEAM PROOUCT)ON ARC*COOET)e 546-2700 October 4I 1984 Director of Nuclear Reactor Regulation Attention: Nr. Walter A. Paulsoni Acting Chief Operating Reactors Branch No. 5 U.S. Nuclear Regulatory Commission Washington< D.C. 20555

Subject:

Appendix RI Alternative Shutdown System R. E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Hr. Paulson:

By letter dated January 16I 1984I Rochester Gas and Electric submitted a report titledi "Appendix R Alternative Shutdown System>" which described RGSE proposals to provide safe cold shut-down capability following a fire anywhere in the plant as required by 10 CFR 50 Appendix R. The report described local control capabilityi limited upgrading of fire area boundaries> installa-tion of protection for selected power> control and instrumentation circuits and limited exemption requests where existing plant features or proposed modifications provide a level of fire protec-tion commensurate with the hazards in the plant.

During review of the report> NRC Staff members have requested that revisions be made to reflect current NRC positions and to clarify- the actions that RGGE proposes to take. Revision 1 of the report< being submitted under separate cover> reflects the requested changes and clarifications. Because the report is lengthy and it is being reissued in its entirety> a summary of the actual changes to the report is included in Attachment A to this letter.

On Nay 10I 1984 the Commission issued an exemption to the schedular requirements for the alternative shutdown system as set forth in 10 CFR 50.48(c)(4). The exemption is effective until the startup from the 1986 refueling outage. RG6E has been actively working to implement the alternative shutdown system described in the report and has discussed the report with the Staff on several occasions. Howeveri because RG6E is reluctant to continue a substantial commitment of resources without NRC approval of the proposed plans> RG6E requests that your written concurrence be provided as soon as possible. RGGE staff will be available at your convenience to assist in your review.

e r truly yours>

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F R er W. Kober ))

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ATTACHMENT A The Ginna Appendix R Alternative Shutdown Report has been revised to incorporate recent Staff clarifications and address Staff questions. The changes are indicated by revision bars in the right-hand margin of the report and are outlined below.

(1) Several fire areas were regrouped into larger fire areas. The smaller original f ire areas then became f ire zones of the new larger fire areas.

(a) Fire Area BRlA became a fire zone of Fire Area CC.

(b) Fire Areas IBNg IBSEN ABO and N2 are all now fire zones of the new Fire Area ABI.

(2) One new exemption request was added to address the nonrated design of the fire barrier located in Fire Zone EDGY.

(3) The exemption request concerning one-hour and three-hour equivalent protection has been revised to refer only to one-hour equivalent protection barriers.

(4) The exemption request concerning structural steel has been deleted.

(5) A new exemption request concerning the barriers around the Battery Rooms was added.

(6) A discussion of fire detector locations and new detectors to be added has been included.

(7) Responses to NRR Staff questions were incorporated as follows:

(a) A discussion of two-wire ungrounded dc circuits was added to explain why a similar> previously granted exemption applies to the Ginna plant.

(b) A clarification was added to state that fire brigade members are not called upon for hot shutdown activities.

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(c) Section 3 was revised to clarify the definition of activities that are considered alternative shut-down.

(d) A clarification concerning fuse removal was added to Section 3.

(e) Connection of spare source range electronics will be accomplished using only a procedure and is not considered repair.

(f) Spray shields to prevent cooling of fusible links by adjacent spray heads will be incorporated at specific locations.

(g) The NRC guidance of Generic Letter 83-33 has been incorporated for some barriers.

In addition to these revisions to the report> portions of the text were rewritten for the sake of clarity and to include editorial comments. These changes are not associated with the technical update and did not revise the meaning of the original report. The editorial revisions are not indicated by revision bars in the right hand margin.