ML14183A108
| ML14183A108 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 07/30/1987 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | Carolina Power & Light Co |
| Shared Package | |
| ML14183A109 | List: |
| References | |
| NUDOCS 8708060038 | |
| Download: ML14183A108 (6) | |
Text
0.g 7590-01 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of
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Docket No. 50-261 CAROLINA POWER & LIGHT
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COMPANY
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H. B. ROBINSON STEAM ELECTRIC
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PLANT, UNIT NO. 2
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EXEMPTION I.
The Carolina Power & Light Company (CP&L or the licensee) is the holder of Operating License No. DPR-23 that authorizes operation of the H. B.
Robinson Steam Electric Plant, Unit No. 2. The license provides, among other things, that the H. B. Robinson Steam Electric Plant, Unit No. 2, is subject to all rules, regulations, and Orders of the Commission now or hereafter in effect.
The station is a single-unit pressurized water reactor at the licensee's site located in Darlington County, South Carolina.
II.
On November 19, 1980, the Commission published a revised Section 50.48 and a new Appendix R to 10 CFR Part 50 regarding fire protection features of nuclear power plants. The revised Section 50.48 and Appendix R became effective on February 17, 1981.
Section III of Appendix R contains 15 subsections, lettered A through 0, each of which specifies requirements for a particular aspect of the fire protection features at a nuclear power plant.
One of these subsections, III.J, is the subject of the licensee's exemption request.
--8708060038 870730 PDR ADOCK 05000261.
FPDR
-2 Section III.J, of Appendix R to 10 CFR Part 50, Emergency Lighting, requires 8-hour battery powered lighting units in areas needed for operation of safe shutdown equipment and along access and egress routes thereto.
III.
By letter dated June 29, 1984, as supplemented January 16, 1985, CP&L requested approval of exemption from the technical requirements of Section III.J of Appendix R to 10 CFR Part 50 concerning the need for 8-hour battery powered lighting units in areas needed for operation of safe shutdown epuipment and along access routes. The exemption request relates to the access routes to the charging pump room, component cooling water heat exchanger room, battery room, safety injection pump room and the service water intake structure. The licensee also requested an exemption for the contain ment and residual heat removal (RHR) pit areas where manual, cold shutdown operations are required and/or where possible repairs may be needed. The staff's evaluation of the licensee's request is provided below.
The reason for requiring 8-hour battery powered emergency lighting is to ensure that at least minimal lighting is available for the performance of manual actions necessary for safe shutdown after a fire. Usually manual actions are required for valve alignment, repairs and pump control operations. The licensee has stated that a fire on the ground level at the south end of the auxiliary building hallway would prevent access to dedicated shutdown equipment in the charging pump room and the component cooling water heat exchanger room. Similarly, a fire in the emergency switchgear room would
-3 prevent access to the DC distribution panels in the battery room. A fire at the north end of the auxiliary building hallway on the ground level would prevent access to the SI-864 A and B valves in the safety injection pump room. Also, manual operation of service water valve V6-12D, located at the intake structure, would require emergency lighting. The licensee has stated that due to the numerous alternate access pathways, a large number of fixed emergency lighting units would have to be installed, and the routing of associated cabling to provide the necessary electrical power for redundant lighting is not practicable.
The licensee justified the proposed e'emptions for the limited circumstances where a fire may prevent access through the south end of the auxiliary building to the above stated areas. The licensee's justification is based on the availability of an assured alternate path where 8-hour battery powered lighting units are provided. In the areas where lighting units would not be installed, dedicated portable, hand-held lighting would be provided for the operator to perform the necessary functions. The licensee justifies this approach on the basis that the availability of dedicated portable hand-held lighting provides a level of emergency lighting equivalent.to that required by Section III.J for the above areas.
The technical requirements of Section III.J of Appendix R are not expressly met at the intake structure and along the access route to the safety injection pump room because fixed, individual 8-hour battery powered lighting units are not provided for safe shutdown.
-4 At the north end of the auxiliary building, the staff was concerned about the availability of a reliable means of illumination and whether the path of travel would be unobstructed and easily traversed. The licensee has identified alternate access paths to the required equipment or alternate equipment that would provide the same functions. For example, the alternate access route to the charging pump room is from the second level of the auxiliary building adjacent to the non-regenerative and seal water heat exchangers, to the component cooling water heat exchanger room from the turbine building via the exterior door in the south,wall of the room, and to the battery room via the chemical batch addition room. These alternate routes are provided with fixed, 8-hour battery powered units. Furthermore, the alternate access route to the safety injection pump room follows the exterior of the auxiliary building along the east and north sides of the safety injection pump room exterior door. Portable hand-held lighting will be provided for operator access to the safety injection pump room. Permanent emergency lighting is provided inside the safety injection pump room to operate the required equipment. Portable lights will be provided in the control room for performing the required functions at the service water intake structure. These portable lights will provide adequate illumination for the operators to access the intake structure and operate valve V6-12D.
Since the only manual actions required inside the containment and RHR pit are for the operation of valves for cold shutdown, sufficient time is available for the licensee to take appropriate action to re-energize the normal containment lighting units prior to containment entry.
-5 Based on the above evaluation of alternate access routes and provision for portable, hand-held lighting, the staff concludes that adequate lighting will prevail to access areas and perform necessary safe shutdown functions.
Therefore, the licensee's request for exemptions from the requirements of Section III.J of Appendix R for certain paths to the charging pump room, component cooling water heat exchanger room, DC distribution panels in the battery room and safety injection pump room is acceptable and should be granted. Furthermore, the staff concludes that the installation of 8-hour battery powered emergency lighting units inside the containment would not significantly improve the level of fire protection for this fire area.
Therefore, their omission is an acceptable exemption from Section III.J of Appendix R, and application of the regulation in this particular circumstance is not necessary to achieve the underlying purpose of the rule.
IV.
Accordingly, the Commission has determined that, pursuant to 10 CFR 50.12(a), that (1) these exemptions as described in Section III are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common 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 Part 50. Therefore, the Commission hereby grants the following exemptions from the requirements of Section III.J of Appendix R to 10 CFR Part 50:
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- 1. Access and egress routes to the:
- a. charging pump room;
- b. component cooling water heat exchanger room;
- c. battery room;
- d. safety injection pump room; and
- e. service water intake structure.
- 2. Containment and RHR pit areas where manual, cold shutdown operations are required and/or where possible repairs may be needed.
Pursuant to 10 CFR 51.32, the Commission has determined that the granting of this exemption will have no significant impact on the environment.
For further details with respect to this action, see the request for exemption dated June 29, 1984, as supplemented January 16, 1985, which are available for public inspection at the Commission's Public Document Room, 1717 H Street, N. W., Washington, D. C., and at the Hartsville Memorial Library Home and Fifth Avenues, Hartsville, South Carolina 29535.
This exemption is effective upon issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Steven A. Varga, Director Division of Reactor Projects -
I/II Office of Nuclear Reactor Regulation Dated at Bethesda, Maryland, this 30 day of July
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