ML20070G223
| ML20070G223 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 12/08/1982 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | NORTHERN STATES POWER CO. |
| Shared Package | |
| ML20070G226 | List: |
| References | |
| TAC-11094, TAC-11095, NUDOCS 8212220048 | |
| Download: ML20070G223 (7) | |
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Enclosure-NUCLEAR REGULATORY COMMISSION In the Matter of
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NORTHERN STATES POWER I Docket Nos. 50-282 and 50-306 COMPANY
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(Prairie Island Nuclear Generating )
Plant, Unit Nos. I and 2)
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EXEMPTION I.
The Northern States Power Company (the licensee) is the holder of
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- Facility Operating License Nos. DPR-42 and DPR-60 which authorize-operation of the Prairie Island Nuclear Ger.erating Plant, Unit Nos. I and 2.
These licenses provide, among other things, that they are subject to all rules, regulations and Orders of the Commisson now or hereafter in effect.
The facility comprises two pressurized water reactors at the 1icensee's site located in Goodhue, Minnesota.
II.
On November 19, 1980, the Commission published a revised Section 10 CFR 50.48 and a new Appendix R to 10 CFR 50 regarding fire protection features of nuclear power pl:nts (45 F.R. 76602).
The revised Section 50.48 and Appendix R became effective on February 17, 1981.
Section 50.48(c) established the schedules for satisfying the provisions of Appendix R.
Section III of Appendix R contains fifteen 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 fifteen subsections, III.J. is the subject of this exemption request.
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8212220048 821200 PDR ADOCK 05000
. Subsection III.J specifies 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.
Section 50.48(c) requires completion of all modifications to meet the provisions of Appendix R within a specified time from the effective date of this fire protection rule, February 17,1981,.except for.mo.difi..
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cations to provide alternative safe shutdown capability.
By letters dated November 16 and December 1,1981, Northern States Power Company requested exemptions from 10 CFR 50.48(c) with respect to the requirements of Subsection III.J of Appendix R as follows:
" Extend the implementation date in paragraph (c)(3) for modifi-cations required by Appendix R Subsection III.J that do not
.. require prior NRC approval but require plant shutdown, from the first refueling shutdown or extended outage commencing after 180 days from the effective date of Appendix R for each unit to the refueling outage scheduled for autumn of 1982 for Unit I and scheduled for spring of 1982 for l'zit 2."
Section 50.48(c)(3) specifies the installation schedule of those fire protection features such as emergency lighting (III.J) that require a plant shutdown to complete the installation. The installation schedule in Section 50.48(c)(3) r quires the completion of the installation of such fire protection features during the first refueli.ng outage commencing after 180 days from the effective date of Appendix R-(February 17,1981).
Hence, Section 50.48(c)(3) requires the licensee to complete the installa-tion of the emergency lighting (III.J) during the first refueling outage commencing after August 17, 1981 for each unit.
On May 4, 1982, the Commission granted Northern States Power Company an extension from the schedular requirements of 10 CFR 50.48(c)(3)
. for Unit I until the end of autumn 1982 outage based on facts that had been presented by that date. An exemption was not granted for Unit 2 since the licensee's commitment date by which installation would be completed complied with the schedule'specified in 50.48(c)(3).
By letter dated May 20, 1982, the licensee requested further schedular relief from 10 CFR 50.48(c) in regard to the installation of emergency lighting. Specifically, the request would extend the.
deadline for completing the installation for both units to the end.of December 1982.
The licensee by the same letter also stated that a plant shutdown is no longer considered necessary at either unit ir. order to implement the Subsection III.J requirements. Because of these changed circum-sta,nces, the exemption from the schedular r.
ements of 10 CFR 50.48(c)(3) granted on May 4,1982 for Unit 1 is no longer valid.
1 Under conditions described.w the licensee's letter dated May 20, 1982 the schedular requirement for Subsection III.J is established in 10 CFR 50.48(c)(2).
This subsection requires that the installation of emer-gency lighting be completed by November 17, 1981, nine months from the effective date of the rule.
The staff informed the licensee by letter dated July 29, 1982 that in order to consider the exemption request, the licensee would be required to submit a complete and detailed chronology of the efforts to implement Subsection III.J commencing with the publicat' ion of the fire protection rule on November 19, 1980 to the present and justify in detail tc.e proposed schedule to complete the insta11ation for both t
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4-j units by January 1, 1983. The licensee by letter dated August 23, 1982 provided additional information supporting the exemption request including a detailed chronology of the efforts to implement Subsection III.J.
III..
Tha. licensee stated that for several months following the publica-tion of Appendix R the licensee believed that the eUting emergency
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lighting' system, with minor modifications, would satisfy the requiremen'ts
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of Subsection III.J.
The existing power source for emergency lighting is automatically transferred to the DC power system which provides power well in excess of the required eight-hour capability.
In addition the existing emergency lighting system had been reviewed and found acceptable by the NRC staff based on established positions prior to tM-issuance of Appendix R.
It was not until July 13, 1981 that addi-
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tional inforination related to the staff's interpretation of the require-ments of Subsection III.J was made known to the licensee. Specifically, using a central power source was found unacceptable unless it could be 1
shown that a postulated fire in one area of the plant could not cause the loss of lighting in another area.1 This interpretation of Sub-section III.J requiremen s makes it impractical for any permanently wired emergency lighting system, such as that which now exists at the l
Prairie Island Nuclear Generating Plant, to meet the' requirements of the regulation.
Eftorts to comply with Subsection III.J were redirected' on July 13, 1981 to procure and install satisfactory local battery powered lighting units.
I This finding was contained in our letter to the licensee in regard to an exemption request for the Monticello Plant dated July 13, 1982.
. When the licensee prepared the exemption requested"by letter dated November 16, 1981, the safe shutdown analysis had not progressed sufficiently to identify the exact locations for operation of safe shutdown equipment under Subsection III.G of Appendix R.
It appeared at this point in the design that several areas requiring emergency lighting would be in parts of the plant where radiation levels made it
. imprudent to perform the modifications during plant operations.
On this basis the licensee requested an exemption from the schedular,
requirements of 10 CFR 50.48(c)(3).
It was not until May 1982 that the safe shutdown analysis of Subsection III.G was completed to a point where all areas of the plant needing emergency lighting could be identi fied. The plant staff determined that emergency lighting could be installed in all of these identified areas during plant operation with-out disrupting the operation of critical plant equipment or exposing plant personnel to excessive radiation levels.
Ohce these circumstances were known, the licensee, by letter dated May 20, 1982, submitted a second request for a schedule exemption, asking for an extension in the time allowed for completing Subsection III.J modification to January 1,1983 fo'r both units.
As noted above, the appropriate section for the exemption was now stated to be C-2 rather than C-3.
Delays developed when the licensee sought to purchase seismically qualified equipment - a design feature that exceeds the requirements of Subsection III.J. This delay occurFed when the foreign battery supplier was no longer a reliable source which lead to further delays in the licensee's efforts to purchase suitable fighting units. The U
purchasing of the lighting units were also thwarted by a contract
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. dispute between the lighting unit vendor and the manufacturer of the batteries.
In addition, the engineering analysis for emergency lighting resulted in unforeseen delays associated with properly identifyingallof the areas where lighting units would be needed until the safe shutdown analysis under Subsection III was nearly completed, which affected the total number of lighting units needed to be pur-
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chased.
Based on our consideration of these circumstances, we conclude that the licensee made proper application of available resources in a best effort to provide seismically qualified lighting. However, the time allowed proved to be insufficient to permit full implementation.
In addition, we have determined that as an interim compensatory measure the existing emergency lighting, although not fully in compliance with III."J, and in conjunction with the portable lighting units that are available for use by the operators and members of the fire brigade can provide emergency lighting as needed until the installation of the III.J units is achieved.
On this basis the staff has judged that the request for exemption to allow additional time to complete the installa-tion of the emergency lighting for both units until January 1,1983 should be granted.
IV.
Accordingly, the Commission has determined that, pursuant to l
10 CFR 50.12, an exemption is authorized by law and will not endanger 1
life or property or the common defense and security and is otherwise
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l in the public interest and hereby grants the fo11owing exemptions i
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. with. respect to.the requirements of Subsection III.J of Appendix R to 10 CFR 50:
Extend the implementation date in paragraph (c)(2) for installation of modifications required by Appendix R Subsection III.J for both units, that do not require prior NRC approval or plant shutdown, from nine months after February 17, 1981 to January 1, 1983.
The NRC staff had determined that the granting of this Exemptior.
will not result in any significant environmental impact and that pu'rsuant to 10 CFR 51.5(d)(4) an environmental impact statement or negative declaration and environmental impact appraisal need not be prepared in connection with this action.
FOR UCLEAR REGULAT COMMISSION Haro De rector Office of Nuclear Reactor Regulation Dated at Bethesda, Maryland this 8th day of December, 1982 e
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