ML20041C863
| ML20041C863 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 02/26/1982 |
| From: | Bayne J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20041C864 | List: |
| References | |
| JPN-82-24, NUDOCS 8203020617 | |
| Download: ML20041C863 (3) | |
Text
POWER AUTHORITY OF THE STATE OF NEW YORK 6
10 COLUMBUS CIRCLE NEW YORK. N. Y.1o019 (2826 397 6200 GEoRo,ET esRRY p
TRUSTEES opa na rs seG OF FICE S JOHN W. BOSTON JOHN S OYSON ras aos T noCEpunts
- PE"'*""A"#8 GEORGELs INGALLS veCs CMaseM AN JOSEPH R. SCHMIEDER as og
. CMIEF RfCHARD M. FLYNN ROBERT I MILLONZ3 LEROY W. SINCLAIR February 26, 1982
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,REoERien R. cLARx JPN-82-24
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Director of Nuclear Reactor Regulation g
U.S. Nuclear Regulatory Commission UbCUIND Washington, D.C.
20555 Q
MAR 1 1982=- q Attention:
Mr. Harold R. Denton, Director
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Subject:
James A. FitzPatrick Nuclear Power Plant g
j Docket No. 50-333
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Request for Exemption from Implementation of Provisions of 10CFR50, Appendix R, Section III.G.2
References:
1.
Letter from J.P. Bayne (PAGNY) to T.A.
Ippolito (USNRC) dated June 22, 1981 (JPN-81-45) 2.
Letter from J.P. Bayne (PASNY) to T.A. Ippolito (USNRC) dated January 22, 1981 (JPN-82-11)
Dear Sir:
As mentioned in the above referenced letter, the Authority submitts herewith 15 copies of a document entitled " Appendix II to Safe Shutdown Analysis Response to 10CFR50 Appendix R Fire Protection of Safe Shutdown Capability."
Per the guidance of the " Supplementary Information" section of 10CFR50, Appendix R, the Power Authority of New York has, for the James A.
FitzPatrick Nuclear Power Plant, reviewed "those previously approved configurations of fire protection that do not meet the requirements as specified in Section III.G to Appendix R."
The results of this review which included the re-examination of the physical separation of safety-related and associated circuits required for safe shutdown in accordance with Appendix R require-ments showed the following:
1.
Fire retardant coatings were not credited as fire barriers; fire retardant coatings were not used at the James A.
FitzPatrick Nuclear Power Plant.
2.
The previously submitted Fire Hazards Analysis and Safe Shutdown Analysis remain correct.
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8203020617 820226 PDR ADOCK 05000333 PDR
3.
Based on this review the separation of cables on the boundary of fire zones RB-1 East and RB-1 West in the HPCI area, the Authority considers that the existing configuration, as discussed in Sections 4.3 and 4.4 of Appendix II of the Safe Shutdown Analysis meets the specific requirements of 10CFR50, Appendix R, Section III.G, thus obviating the need for an exempt-ion.
If the NRC staff does not concur, the Authority requests an exemption to the specific requirements of 10CFR50, Appendix R, Section III.G.2 for this area on the basis that the existing physical, vertical and horizontal separation, coupled with the installed fire protection systems for that area, provides equivalent protection of the public health and safety.
4.
Redundant associated circuits on the boundary of fire zones RB-13B and RB-13C were found to be separated by less than the 20 feet required by Appendix R.
The actual separation distance is approximately 13 feet horizontal.
A detailed evaluation of the actual plant configuration and the results of fire hazards analyses shows the existence of equivalent protection means through a combination of intervening partial height walls, self-closing fire door, installed diverse fire detection systems, remote, manually activated fire suppression systems and through the existing 13 feet of physical separation.
Section 4.1 of the en-closed report includes the detailed exemption request for this configuration.
Accordingly, in accordance with 10CFR50.48 Section (c) (6),
the Power Authority of the State of New York hereby requests exemption from the provisions of 10CFR50, Appendix R Section III.G for the James A.
FitzPatrick Nuclear Power Plant for the specific fire areas as described above.
The basis for the exemption re-quest is that the existing plant configurations provide equiva-lent protection to the public health and safety to that which would be provided by meeting Section III.G of Appendix R in those areas.
The Authority looks forward to the Commission's review and favorable action on the enclosed request and ultimately to the issuance of a closed fire protection Staff Safety Evaluation Report for the James A. FitzPatrick Nuclear Power Plant.
Should you have any questions or require further assistance, please do not hesitate to contact me.
Very truly yours, 1
J. P.
Bayne Senior Vice President Nuclear Generation cc on page 3.
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- JPB/LG:mp cc:
Mr. J.
Linville Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, New York 13093 Mr. Ron Barton United Engineers & Constructors, Inc.
30 S.
17th Street Philadelphia, Pa.
19101 j