ML20006B512
| ML20006B512 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 01/24/1990 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9002050008 | |
| Download: ML20006B512 (5) | |
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BALTIMORE GAS AND ELECTRIC CHARLES CENTER.P.O. BOX 1476 BALTIMORE, MARYLAND 21203 GEORGE C. CREEL -
jgggggy 24, gggQ Vict PassietNt NucLtan ENanov (3o0 aso-assa U. S.' Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Reauest for Exemotion - 10 CFR 50 Anoendix R Gentlemen:
Baltimore Gas and Electric Company, pursuant' to 10 CFR 50.12(a), hereby requests an exemption to provide temporary relief from the requirements of 10 CFR 50 Appendix R, Section III.J. " Emergency Lighting." Additional time is necessary to install permanent 8-hour emergency lighting to assure illumination of those areas required for access and operation of safe shutdown equipment. Certain areas were created as a result of extensive changes to the Calvert Cliffs Nuclear Power Plant (CCNPP) post-fire Alternative Safe Shutdown Procedure.
BACKGROUND i
Based on the guidelines of 10 CFR 50.48(c)(4), the initial! compliance date for Appendix R Section Ill.J was March 27, 1983, in a schedular exemption request dated j
requested an extension of the March _27, 1983 date to i
February ' 23, 1983,
'"a September 1,1983. '..n Commission granted this exemption in a Safety Evaluation Report p
transmitted by a letter dated March 15, 1983.
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Compliance with 10 CFR Appendix R Section 111. J. was achieved by September 1,1983 and N oc_
the Appendix R compliance audit of CCNPP in March 1984 did not identify any emergency -
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!ighting deficiencies. Details of the Appendix R compliance audit may be found in NRC
. og-Combined Inspection No. 50-317/84-04 and 50-318/84-04 submitted on May 8,1984
$U As part of Our ongoing long term Appendix R compliance program, the. Appendix R gg post-fire Alternate Safe Shutdown Procedure (AOP-9) was reviewed.
Several
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in c procedural, hardware, and manpower deficiencies were identified. A thorough revision 8
of AOP-9 was performed including the addition of numerous steps and the installation i
gg of several equipment modifications. Details of the deficiencies and corrective actions p a.u.
may be found in LER 317-89-009.
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Document Control Desk c
January 24, 1990 Page 2 l
10 CFR 50 Appendix R, Section III.
J., " Emergency Lighting", states:
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" 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."
An' initial review of a draft AOP-9 revision has identified - certain areas where insufficient emergency lighting levels may exist to access and operate safe shutdown equipment. As a result of this initial review, BG&E - will perform a complete review of the 8-hour emergency lighting capabilities in conjunction with the final revised I
procedures. New emergency lighting units will be provided where needed.
i A considerable amount of time will be needed in order to determine the new emergency lighting ' needs, and then to design and install the lights, it is anticipated that it will take approximately six months beyond the start up of each unit to complete the installation of the new requisite 8-hour emergency lighting for that unit. Unit 1 is presently shutdown and is expected to start up in February 1990. Unit 2 is presently i
shutdown in an extended refueling outage.
ANALYSIS In early 1989 we began a long term review of our Appendix R compliance program. Among the first compliance items reviewed was the Appendix R post-fire Alternate Safe Shutdown Procedure. The review of this procedure (Abnormal Operating Procedure AOP-9) concluded that several procedural, hardware, and manpower deficiencies existed. This led to an extensive AOP-9 revision and some equipment modifications to correct the identified deficiencies. The procedural and equipment changes created new areas which l
s require 8-hour emergency lighting per 10 CFR 50 ' Appendix R,Section III. J.
l The basic set of shutdown systems has remained the same between the original and revised Appendix R procedures. Therefore, the majority of -areas ' requiring 8-hour '
emergency lighting has not changed and. the required emergency lighting is available for equipment operation and access. In those areas where 8-hour emergency lighting may need to be installed as a result of the AOP-9 revision, there are twc interim compensatory measures available. First is the. existing 1 1/2-hour standard emergency lighting which was installed primarily for. emergency egress purposes. - These 1 1/2-hour-lighting units will provide illumination during the most critical phase of the AOP when auxiliary feedwater and A.C. power are being restored (during - the. first hour).
Activities after this point are not as critical from a time standpoint. The ' second
.. interim measure is portable handlights. Portable handlights and replacement batteries are located in the safe shutdown equipment locker in equipment pouches for each. watch
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station utilized during A OP-9. The handlights will provide illumination for access i
and equipment operation needed in those areas without adequate emergency lighting.
The potential need for the emergency lighting during the interim - period is considered to be low. A fire of sufficient magnitude to require implementation of alternative safe shutdown procedures is unlikely. Fire detection capability-is ' provided' in all :
alternate safe shutdown areas. The fire detection systems provide early warning of a fire condition which normally - permits extinguishment of the fire while it is still in -
an incipient stage.
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- t Document Control Desk l
Jrtnuary 24, 1990 Page 3 Fire suppression systems are also installed in many plant areas. Halon systems are installed in the 4 switchgear rooms, the cable spreading tooms, and the plant computer rooms. Sprinkler systems are installed in the. remaining alternative safe shutdown l'
areas (except in the Control Room for which there is an approved exemption request).
Fire suppression systems are designed to suppress a fire before it can reach a stage where it can spread beyond the point of origin.
Based on the above, the probability of a severe fire occurring which requires i
implementation of an Appendix R shutdown procedure is low. Emergency lighting is only needed if this type of fire occurs concurrently with a loss of off-site power or fire damage to the electrical distribution system. The likelihood of a severe fire concurrent with a loss of off-site power during the interim period is even lower.
SCHEDULE It is anticipated that it will take 'approximately six months after the restart of each unit to have that Unit's emergency lighting reviewed, designed, parts obtained, and installed. Therefore, this temporary exemption request is for n period - of six months after the start up of each unit. The. basis for utilizing the start up date of a unit -
as the start date for the exemption request is that approval of the new AOP-9 procedures is not yet complete. The approval of the new procedures is, however, a restart commitment.
i COMPENSATORY MEASURES The following compensatory measures will be implemented during-the requested temporary exemption - period. Existing 1
1/2-hour emergency lights will be - utilized where installed.- Portable handlights will be placed in the ' equipment pouches assigned to each shutdown procedure watch station. ' These pouches are located in the locked Safe Shutdown Equipment Locker adjacent to each unit's alternate shutdown panel. The handlights in these lockers will be inventoried and ' inspected on a monthly basis. A second complete set of handlights and replacement batteries will be' stored in the 45 foot Turbine Building Operations Storage Cage, (in the event therelis a fire in the rooms containing the auxiliary shutdown panels). These will also be _ - inventoried and inspected on a monthly basis. Extra batteries will also be stored in the Alternate-Safe Shutdown Equipmeni Lockers.
10 CFR 50.12 states that the Commission may grant exemptions' from the requirements of '
regulations contained in 10 CFR' 50 provided that (1)- the exemption ' is authorized by law; (2), the exemption will not present an undue risk. to the public health and safety; (3) the exemption-is consistent with the common defense and security; and (4) special circumstances, as defined in 10 CFR 50.12(a)(2), are present.
1.
The Reauested Exemotion is Authorized by Law No law exists which would preclude the activities covered by this _ exemption request. Thus, the Commission is authorized to grant this exemption. Generic.
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' Document Control Desk January 24; 1990' Page 4 Letter 86-10 " Implementation of Fire Protection' Requirements" address schedular exemptions from Appendix R requirements. This request meets the criteria of that document in addition to those of 10 CFR 50.12.
.t 2.
The Reauested Exemotion Does Not Present an Undue Risk to the Public Health and i
Safety The existing 1~ 1/2-hour emergency lighting and portable handlights provide.
L adequate. interim compensatory measures in lieu of the required 8-hour emergency
'ighting.
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interim measures will remain in place until permanent.8-hour i
emerbency leh:h:g can be installed.
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Existing 8-hour emergency lighting will provide the necessary ' illumination for equipment operation and access in the majority of safe shutdown areas.
'I In areas without existing 8-hour emeigency lighting, existing i 1/2-hour emergency lighting. or portable handlights will provide' an adequate source
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of alternate lighting.
f Fire ' detection and suppression systems are installed in virtually all the alternative safe shutdown areas.
This minimizes the likelihood and.
potential severity of a fire in these areas.
Off-site power. must be lost concurrent-with - a severe fire for ~ emergency lighting to be ' required. The likelihood of this scenario occurring during the requested exemption period is very low.
i 3.
-The Reauested Exemotion Will Not Endanner the Common Defense and Security The common defense and security are not at issue in this exemption request.
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4.
Soecial Circumstances are Present Which Necessitate the 'Reauest for an Exemotion to the R nulations of 10 CFR-50 Anoendix ' L Sections III.D.2(a) and ' III.D.3.
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- Per '10 CFR 50.12. (1)(2),. the following special circumstances are present:
a.
The exemption would provide only ' temporary relief: from the regulation and we have made continued good faith efforts to comply - with ' the regulations.
The exemption is = requested for a period of 6 months ' past the start up of p
- each unit.
b.
Compliance with the regulation would result in undue hardship and cost-to:
BG&E significantly in excess of others who have been similarly situated tin the past. It would unnecessarily delay plant start up by up to six months.:
Many temporary exemptions to this regulation have been issued in the past.
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q Documsnt Control Desk
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/ Janusry. 24,: 1990 t
Page 5
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The exemption is necessary as' a result of our good faith - efforts - to-- assure :
continued compliance with Appendix R through our ongoing Appendix R compliance program. We should not be penalized for putting forth such good ;
faith efforts now or in the future.
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Since the promulgstion of Appendix R, we have expeditiously strived to-meet its. requirements. Our : proposed schedule-for completion represents ~
best.
a effort under. the circumstances and adequate. interim ' measures :will! be 4
implemented until compliance is achieved.
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. Pursuant to 10 CFR 370.21,' we are including BG&E check No. 1070859 in the amount of.-
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$150.00 to the NRC to cover. the application fee for this request.
Should you have any further questions. regarding this' matter, we will be ' pleased. to discuss them with you.
Very. truly, yours, b
GCC/CDS/db i
cc:
D. A'. Brune,.' Esquire.-
J.. E.
Silberg, Esquire R. A.Capra, NRC D. G. Mcdonald, Jr., NRC W. T. Russell, NRC J
E. Beall, NRC
. T. Magette, DNR N
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