ML14183A338
| ML14183A338 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 06/03/1996 |
| From: | Varga S NRC (Affiliation Not Assigned) |
| To: | CAROLINA POWER & LIGHT CO. |
| Shared Package | |
| ML14183A339 | List: |
| References | |
| NUDOCS 9606100112 | |
| Download: ML14183A338 (5) | |
Text
7590-01 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.
Carolina Power and Light Company (CP&L or the licensee) is the holder of Facility Operating License No. DPR-23, which authorizes operation of the H. B.
Robinson Steam Electric Plant, Unit No. 2 (HBR), at steady-state reactor power level not in excess of 2300 megawatts thermal.
The facility consists of one pressurized water reactor located at the licensee's site in Darlington County, South Carolina. The license provides, among other things, that it is subject to all rules, regulations and Orders of the Nuclear Regulatory Commission (the Commission or NRC) now or hereafter in effect.
II.
Section III.J of Appendix R to Part 50 of Title 10 of the Code of Federal Requlations (10 CFR Part 50) requires that emergency lighting units with at least an 8-hour battery power supply be provided in all areas needed for operation of post-fire safe shutdown equipment and in access and egress routes thereto. The NRC may grant exemptions from the requirements of the regulations which, pursuant to 10 CFR 50.12(a), are (1) 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) present special 9606100112 960603 PDR ADOCK 05000261 F
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-2 circumstances. Special circumstances exist whenever, according to 10 CFR 50.12(a)(2)(ii), "Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule...."
III.
By letters dated February 2, 1995, May 15, 1995, and September 29, 1995, Carolina Power & Light Company (the licensee), requested an exemption from certain technical requirements of Section III.J of Appendix R to 10 CFR Part 50 for HBR.Section III.J of Appendix R requires that emergency lighting units with at least an 8-hour battery power supply be provided in all areas needed for operation of post-fire safe shutdown equipment and in access and egress routes thereto. The licensee plans to implement procedure enhancements to its post-accident safe shutdown procedure that would require manual operation of certain valves. The licensee proposed to use the diesel-backed security lighting system for access and egress to, and operation of, auxiliary feedwater (AFW) valves AFW-1 and AFW-104 and instrument air (IA) valve IA-297, stating that the use of the diesel-backed security lighting system will provide an equivalent level of fire safety to that achieved by compliance with Section III.J of Appendix R to 10 CFR Part 50 for access and egress to, and operation of, valves AFW-1 and AFW-104, located in fire zone 33, and valve IA-297, located in fire zone 25.
IV.
Valves AFW-1, AFW-104, and IA-297 are located in outdoor areas within the protected area. These areas and the access and egress paths do not have 8-hour fixed battery-operated emergency lighting as required by Section III.J of Appendix R to 10 CFR Part 50.
K:
3 Valves AFW-1 and AFW-104 are located in fire zone 33 at the bottom of the condensate storage tank (CST).
Failure to manually isolate valves AFW-1 and AFW-104 could result in overfilling the CST with service water after switchover of the AFW cooling source from the CST to the service water system.
These AFW valves are located in outdoor areas within the protected area and are provided with lighting from the security lighting system. However, the licensee may need to manually operate these valves during the hours of darkness. Because the security lighting system is also backed by a standby diesel generator, the licensee would like to rely on the security lighting system with its standby diesel generator as an acceptable alternative fire protection configuration equivalent to that achieved by conformance with the requirements of 10 CFR Part 50, Appendix R, Section III.J.
Valve IA-297 is located in an outdoor area within the protected area near the southeast corner of the turbine mezzanine in fire zone 25 next to the steam dump accumulator. The HBR safe shutdown analysis takes credit for the availability of the main steam safety valves. The use of the nitrogen backup to the main steam power-operated relief valves is a contingency evolution for coping with a fire in the charging pump room. The licensee has already committed to provide emergency lighting with at least an 8-hour battery power supply for the main steam isolation and relief valve area, also in the southeast corner of the turbine building mezzanine. The licensee would rely on that planned emergency lighting in the vicinity of IA-197 as well as the security lighting system with its backup diesel generator to ensure the light necessary to take the actions described by the licensee.
The manual actions would be limited to operating valves AFW-1, AFW-104.
and IA-297 over their full travel, with no requirement to partially open or
-4 close a valve, by relying on instruments, or other means, to determine valve travel.
In the licensee's submittal of September 29, 1995, the licensee confirmed that a walkdown was conducted in the areas for which the exemption was requested. With the normal lighting turned off, the light provided solely by the security lighting system was adequate for access and egress to, and operation of, valves AFW-1, AFW-104, and IA-297. During a telephone conference call on December 1, 1995, the licensee confirmed that postulated fires requiring the operators to travel to and operate valves AFW-1, AFW-104, and IA-297 would not affect the security lighting system. In addition, the security lighting system is backed by a standby diesel generator that has been very reliable; records indicate only two failures in 250 surveillance starts.
However, none of the failures were failures to start but, rather, failures to come up to rated speed within the prescribed time of 10 seconds. Should the diesel fail to start, procedure OP-926, "TSC/ EOF/ PAT Diesel Generator,"
provides instruction for manually starting the diesel, and such an action would be initiated by a call to the control room operators. Therefore, in the event of a fire that requires manual operation of valves AFW-1, AFW-104, and IA-297, or in the event of a loss of offsite power, there is reasonable assurance that the security lighting system will be available and will provide the light necessary to take the actions described above.
On the basis of this evaluation, the NRC staff has concluded that the use of the diesel-backed security lighting system will provide an equivalent level of fire safety to that achieved by compliance with Section III.J of Appendix R to 10 CFR Part 50 for access and egress to, and operation of, valves AFW-1 and AFW-104, located in fire zone 33, and valve IA-297, located in fire zone 25.
-5 The Commission, thus, has determined that, pursuant to 10 CFR 50.12, the exemption requested by the licensee's letters dated February 2, 1995, May 15, 1995, and September 29, 1995, as discussed above, is authorized by law and will not endanger life or property and is otherwise in the public interest. Furthermore, the Commission has determined, pursuant to 10 CFR 50.12(a), that special circumstances as set forth in 10 CFR 50.12(a)(ii) are present and applicable in that application of the regulation in these particular circumstances is not necessary to achieve the underlying purpose of the rule.
The Commission hereby grants an exemption from the technical requirements of 10 CFR Part 50, Appendix R, Section III.J, for the use of the diesel-backed security lighting system for access and egress to, and operation of, valves AFW-1 and AFW-104 and IA-297.
Pursuant to 10 CFR 51.32, the Commission has determined that granting of this exemption will have no significant effect on the quality of the human environment (61 FR 6044).
This exemption is effective upon issuance.
FOR THE NUCLEAR REGULATORY COMMISSION ven A. at a, 1ctor Division of Reactor rojects -
I/II Office of Nuclear Reactor Regulation Dated at Rockville, Maryland this 3rd day of June 1996