ML14183A228
| ML14183A228 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 10/08/1992 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | Carolina Power & Light Co |
| Shared Package | |
| ML14183A229 | List: |
| References | |
| NUDOCS 9210160190 | |
| Download: ML14183A228 (5) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
CAROLINA POWER & LIGHT COMPANY
)
Docket No. 50-261 (H. B. Robinson Steam Electric
)
Plant, Unit No. 2)
)
EXEMPTION I.
The Carolina Power & Light Company (the licensee) is the holder of Operating License 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.
By letter dated January 22, 1992, the licensee requested exemption from the requirements of Section III.J of Appendix R to 10 CFR Part 50; specifically, the licensee listed 10 areas for which they sought an exemption from the requirement to provide 8-hour emergency lighting in certain areas.
III.
Pursuant to 10 CFR 50.12, the Commission may, upon application by any interested person or upon its own initiative, grant exemptions from the requirements of 10 CFR Part 50 when (1) the exemptions are authorized by law, will not present an undue risk to public health and safety, and are consistent with the common defense and security; and (2) when special circumstances are present. According to 10 CFR 50.12(a)(2)(ii), special circumstances are present when "Application of the regulation in the particular circumstances 9210160190 921008 PDR ADOCK 05000261 PDR L
-2 would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule...."
Section III.J of Appendix R to 10 CFR Part 50 states that "Emergency lighting units with at least an 8-hour battery power supply shall be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto."
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 10 areas for which an exemption from the 8-hour battery powered emergency lighting requirement is sought are areas in which cold shutdown operation and repair activities take place. The licensee proposes to maintain dedicated battery-powered emergency lights at selected locations to permit easy availability to personnel enroute to these 10 areas following a fire.
In their letter of June 29, 1984, the licensee referenced the safe shutdown analysis for H. B. Robinson, Unit 2 (as described in their supplemental submittal dated February 6, 1984) which postulated that cold shutdown operation and repair activities would commence approximately 5 to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after the fire. In letters of July 30, 1987, and June 30, 1988, the staff granted an exemption from the requirement of Section III.J of 10 CFR 50, Appendix R to provide 8-hour battery-powered lights for the containment and RHR pit areas where manual, cold shutdown operations are required and/or where possible repairs may be needed. The same conditions of possible manual, cold shutdown operations and/or repairs exist for these other 10 areas listed in the January 22, 1992, submittal. The technical justification for the
-3 original exemption is also valid for these 10 areas. Specifically:
Battery-powered emergency lighting is required to last 8-hours.
The cold shutdown manual actions and/or repairs will commence 5 to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after the fire. Therefore, effectiveness of the 8-hour battery-powered emergency lighting would be marginal.
Dedicated battery-powered emergency lights will be maintained at selected locations to permit easy availability to personnel enroute to these 10 areas following a fire.
Based on this evaluation, the staff has concluded that the 10 areas listed in the licensee's request for exemption dated January 22, 1992, should, in fact, be exempted from the requirements of Section III.J of Appendix R to 10 CFR Part 50.
In the January 22, 1992, letter, the licensee also requested clarification concerning the earlier Exemption granted by the NRC on June 30, 1988. The evaluation addressed the issue of using the portable battery powered emergency lights both for access to and operation of Service Water Valve V6-120; however, only access to the valve was included in the actual Exemption. The licensee stated that they interpreted this to mean that these portable lights were acceptable also for operation of valve V6-12D. We agree with this interpretation.
IV.
Accordingly, the Commission has determined, pursuant to 10 CFR 50.12, the Exemption as described in Section III is authorized by law, will not endanger life or property, and is otherwise in the public interest; it has also determined that special circumstances exist pursuant to 10 CFR 50.12(a)(2)(ii). Therefore, the Commission grants the following exemption:
-4 Carolina Power & Light Company is exempt from the requirements of 10 CFR Part 50, Appendix R, Section III.J, in that battery-powered emergency lighting need not be provided for the following areas:
Fire Zone/
Description of Area Fire Zone/Area 7/A Auxiliary Building Hallway 11/A Pipe Alley 12/A RHR Heat Exchanger Room 19/A Unit 2 Cable Spreading Room 20/A EI/E2 Emergency Switchgear Room 9/D North Cable Vault 10/E South Cable Vault 25/G Turbine Building, Including 4160V Switchgear Room
/G Outside RHR Pit
/G Central Warehouse and Outside Yard Area The Commission also clarifies that the Exemption granted on June 30, 1988, allows for the operation of service water valve V6-12D at the intake structure using portable lights. It was specifically addressed in Section III on Page 2 of the Exemption sent by NRC letter dated June 30, 1988, and inadvertently omitted from Section IV on page 5.
-5 Pursuant to 10 CFR 51.32, the Commission has'determined that the granting of these exemptions will have no significant impact on the quality of the human environment (57 FR 46410).
FOR HE NUCLEAR REGULATORY COMMISSION ven A. a a,'
recto Division of Reactor Proj c s -
I/II Office of Nuclear Reactor egulation