ML16342C922
| ML16342C922 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 05/05/1995 |
| From: | Adensam E NRC (Affiliation Not Assigned) |
| To: | Rueger G PACIFIC GAS & ELECTRIC CO. |
| Shared Package | |
| ML16342C923 | List: |
| References | |
| TAC-M89105, TAC-M89106, NUDOCS 9505110200 | |
| Download: ML16342C922 (8) | |
Text
1 I
~ 5 (4AIRS AEG0
'0 Cy i~
O
'55 4~
~O
+a*++
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2055&0001 Hay 5, 1995 Hr. Gregory H. Rueger Nuclear Power Generation, B14A Pacific Gas and Electric Company 77 Beale Street, Room 1451 P. 0.
Box 770000 San Francisco, California 94106
SUBJECT:
DENIAL OF RE(VEST FOR EXEHPTION FROH CERTAIN TECHNICAL RE(UIREHENTS OF APPENDIX R TO 10 CFR PART 50 FOR DIABLO CANYON NUCLEAR POWER PLANT, UNIT NOS.
1 AND 2 (TAC NOS.
H89106 AND H89105)
Dear Hr. Rueger:
By letters dated Harch 15,
- 1994, and Hay 25, 1994, Pacific Gas and Electric Company (PG&E), requested an exemption from the technical requirements of Section III.J of Appendix R to Part 50 of Title 10 of the Code of Federal
~tl 1
tlOCPRP ftf 0151 5
5 1PP1 t,Oft 1
and 2 (DCPP).
Section III.J of Appendix R requires that emergency lighting units with at least an 8-hour battery power supply be provided for the access and egress routes to all areas needed for the operation of safe shutdown equipment.
Specifically, you requested approval to use procedurally controlled hand-held portable lights (flashlights) rather than fixed emergency lights for certain access and egress routes for the remainder of plant operation.
By letters dated Harch 2,
- 1983, and July 15,
- 1983, PG&E committed to meet the technical requirements of Sections III.G, III.J, III.L, and III.O of Appendix R.
Therefore, the staff treated your exemption request as a
deviation from your commitment to meet Section III.J of Appendix R.
Your exemption request will hereafter be referred to as "deviation request."
Your letter of Harch 15, 1994, also stated that PG&E considered the deviation request a cost beneficial licensing action as defined in T.
E. Hurley s
memorandum of September 17, 1993, to the U.S. Nuclear Regulatory Commission (NRC) technical staff.
PG&E estimated that approval of the deviation would result in a one-time cost savings of over
$250,000, plus annual recurring cost savings for maintenance and replacement of permanent battery-operated lights.
We have completed our evaluation of the deviation.
On the basis of our evaluation, which included reviews of your submittals of Harch 15,
- 1994, and Hay 25, 1994, telephone calls on June 14,
- 1994, and August 16,
- 1994, walkdowns during a site visit to DCPP during the week of Harch 27,
- 1995, and consideration of previously-approved emergency lighting exemptions/deviations, we have concluded that an adequate technical justification for the proposed deviation on a permanent basis has not been provided.
In addition, we have concluded that the alternative proposed does not provide a level of safety equivalent to that provided by Section'II.J of Appendix R to 10 CFR Part 50 over the long term.
Therefore, we are denying PG&E's request for deviation from the technical requirements of Section III.J of Appendix R to 10 CFR Part 50.
Our safety evaluation is enclosed.
9505ii0200 950505.
PDR AOOCK 05000275 P
PDR IIII;RI.E ggggII II IIP~+
~
~
S4 I>
4'7 j
Hr. Gregory H. Rueger In support of its position that fixed 8-hour battery-powered emergency lighting units are not needed for the access and egress routes identified in the deviation request, PGKE stated in its submittal of Harch 15, 1994, that the NRC had previously approved similar emergency lighting deviations for DCPP in Supplemental Safety Evaluation Reports (SSERs) 23 and 31.
We reviewed these SSERs and found that we did not approve the use of flashlights.
Therefore, we have not approved similar emergency lighting deviations at DCPP.
We did, however, accept the use of alternative fixed emergency lighting, rather than 8-hour battery powered emergency lighting, on the basis of PG&E's analysis that demonstrated that the alternative emergency lighting would be available in the necessary
- areas, including access and egress
- routes, in the event of a fire.
You did not submit a similar analysis with your deviation request of Harch 15, 1994.
During telephone conversations on June 14,
- 1994, and August 16,
- 1994, PGKE informed us that it had not performed such an analysis to support the subject deviation request and that it would not perform such an analysis.
Therefore, although the licensee has stated that alternative fixed lighting is available in some of the affected access and egress
- pathways, the staff does not have assurance that the lighting will be available in the event of a fire.
As part of our review, we also surveyed a number of previously-approved emergency lighting exemptions/deviations.
In addition to approvals based on the availability of alternative fixed lighting (similar to that approved in DCPP SSERs 23 and 31),
we have accepted the use of portable hand-held lights on a limited basis.
- However, as a result of our walkdowns during our site visit, we concluded that your deviation request was not similar to these previous exemption/deviation approvals.
If you have any questions regarding this issue, do not hesitate to contact the Project Hanager, Helanie Hiller, at (301) 415-1323.
Sincerely, Docket Nos.
50-275 and 50-323
Enclosure:
Safety Evaluation cc w/encl:
See next page Elinor G. Adensam, Acting Director Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation
Hr. Gregory M. Rueger In support of its position that fixed 8-hour battery-powered emergency lighting units are not needed for',the access and egress routes identified in the deviation request, PGIIE stated 'in its submittal of March 15, 1994, that the NRC had previously approved similar emergency lighting deviations for DCPP in Supplemental Safety Evaluation Reports (SSERs) 23 and 31.
We reviewed these SSERs and found that we did not approve the use of flashlights.
Therefore, we have not:approved similar 'emergency lighting deviations at DCPP.
We did, however, accept the,use of alternative fixed emergency lighting, rather than 8-hour, battery powered, emergency lighting, on the basis of PGKE's analysis that demonstrated that, the alternative emergency lighting would be available in the necessary'areas, inclu'ding access and egress
- routes, in the event of a fire. 'ou did not submit a similar analysis with your deviation request of Ma'rch:15, 1994.
During.telephone conversations on June 14,
- 1994, and August 16,
- 1994, PGS,E informed us that it had not performed such an analysis to support the subject deviation request and that it would not perform such an analysis'.
Therefore, althou'gh the licensee has stated that alternative fixed lighting is available i'n some of the affected access and egress pathwa'ys, the staff does not have assurance that the lighting will be available in the event 'of a fire.
As part of our review, we also surveyed a number of previously-approved emergency lighting exemptions/deviations.
In addition to approvals based on the availability of alternative fixed lighting (similar to that approved in DCPP SSERs 23 and 31),
we have accepted the use of portable hand-held lights on a limited basis.
- However, as a result of our walkdowns during our site visit, we concluded that your deviation request was not similar to these previous exemption/deviation approvals.
If you have any questions regarding this issue, do not hesitate to contact the Project Manager, Melanic Hiller, at (301) 415-1323.
Sincerely, ORIGINAL SIGNED BY:
Elinor G. Adensam, Acting Director Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket Nos.
50-275 and 50-323
Enclosure:
Safety Evaluation cc w/encl:
See next page DOCUMENT NAME:
DC89105.SER 0ISTR IBUT ION
'ocket PUBLIC PDIV-2 Reading WRussel l/FHiragl i a RZimmerman RSpessard JLieberman, OE EAdensam WBateman HHiller
- See revious concurrence OGC
- EJordan, AEOD GHill (4),
OPA OC/LFDCB JHitchell
- BBeach, Region IV
- KPerkins, WCFO EPeyton Office Name Oate PDIV-2 LA EBeeyn G
95 PDIV-2 PH PDIV-2 D
W g k WBatem@l@
95 95 OFFICIAL, RECORD COPY OGC SHom" 4 24 95 D
W EA en am 95
0 J
r.
)I bC "J
IJ Ig 1
~
I j
'b f
pl) 1 J
jl,",
I l
1
'4 p 5't p
I 9(
s y l
s
~i a g 1
l
/,i~
v
't 1
~'.
r F
iJ A
lq l
I.
\\"
J' l
Mr. Gregory M. Rueger Pacific Gas and Electric Company Diablo Canyon CC:
NRC Resident Inspector Diablo Canyon Nuclear Power Plant c/o U.S. Nuclear Regulatory Commission P. 0.
Box 369 Avila Beach, California 93424 Dr. Richard Ferguson, Energy Chair Sierra Club California 6715 Rocky Canyon Creston, California 93432 Ms. Nancy Culver San Luis Obispo Mothers for Peace P. 0.
Box 164 Pismo Beach, California 93448 Ms. Jacquelyn C. Wheeler P. 0.
Box 164 Pismo Beach, California 93448 Managing Editor The Count Tele ram Tribune 1321 Johnson Avenue P. 0.
Box 112 San Luis Obispo, California 93406 Chairman San Luis Obispo County Board of Supervisors Room 370 County Government Center San Luis Obispo, California 93408 Mr. Truman Burns Mr. Robert Kinosian California Public Utilities Commission 505 Van Ness, Room 4102 San Francisco, California 94102 Mr. Steve Hsu Radiologic Health Branch State Department of Health Services Post Office Box 942732 Sacramento, California 94234 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower & Pavillion 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 Mr. Peter H. Kaufman Deputy Attorney General State of California 110 West A Street, Suite 700 San Diego, California 92101 Christopher J. Warner, Esq.
Pacific Gas
& Electric Company Post Office Box 7442 San Francisco, California 94120 Mr. Warren H. Fujimoto Vice President and Plant Manager Diablo Canyon Nuclear Power Plant P. 0.
Box 56 Avila Beach, California 93424 Diablo Canyon Independent Safety Committee ATTN:
Robert R. Wellington, Esq.
Legal Counsel 857 Cass Street, Suite D
Monterey, California 93940
I