ML20147F974
| ML20147F974 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 02/25/1988 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| Shared Package | |
| ML20147F976 | List: |
| References | |
| NUDOCS 8803080094 | |
| Download: ML20147F974 (7) | |
Text
,
7590-01 OhlTED STATES OF AMERICA r.LCLEAR REGULATOP.Y CCPhiSS10h In the Matter of
)
Docket Nos. 50-200 and
).
50-281 VIRGINIA ELECTRIC i
AND PCWER C0fiPANY
.)
(Surry Pcwer Station,
}
Units 1 ard 2)
)
EXEMPTION I.
The Virginia Electric and Pcwer Company (VEPCO, the licensee) is the holder I
of Cperating License No. OPR-32, which authorizes operation of Surry Power Sta-tion Unit 1, ard Cperating License No. CPR-37, which authorizes cperation of Surry Pcwer Station Unit 2.
The operating licenses provide, araong other things, that the Sorry Power Station is subject to all rules, regulations, and Crders of the Ccmission now or hereafter in cffect.
I The statier certprises twc pressurized water reacters at the licensee's site located in Surry, Virginia.
~
II.
On November 19,19P0, the Comissicn published a revised Section 50.48 and a new Appendix R to 10 CFR 50 regarding fire prctecticn features of nuclear power plants. The revised Section 50.4ft and Appendix R becarre effective en f
February 17, 1981.
Section III of Appendix R contains 15 subsectiers, lettered A through 0, each of which specifies requirements for a particular aspect of the fire protection features at a nuclear power plant. Three of the subsectiens, 1
III.G. III.J. and III.L. are the subject of the licensee's exemption requests.
$k
$O0N $!0 jo
Subsection III.G 2 of Appendix R requires that.one train of cables and equipment necessah to achieve and maintain safe shutdown be maintained free of fire damage by one of the following means:
a.
Separation of cables and equipment and associated nonsafety circuits of redundant trains by a fire barrier having a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rating.
Structural steel forming a part of or supporting such fire barriers shall be protected to provide fire resistance equivalent to that required of the b&rrier.
b.
Separation of cables and equipment and associated nonsafety circuits of redundant trains by a horizontal distance of more than 20 feet with-no intervening combustibles or fire hazards.
In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area, c.
Enclosure of cable and equipment and associated nonsafety circuits of one redundant train in a fire barrier having a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rating.
In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area.
Subsection III.G.3 of Appendix R requires that in areas where alternative or dedicated shutdown is provided, fire detection and a fixed fire suppression system shall also be installed in the area, room, or zone under consideration.
Subsection III.J of Appendix R requires that et,ergency lighting units with at least an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> battery-powered supply be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto.
Subsection III.L.2 of Appendix R requires that certain performance goals for the shutdown functions shall be met.
By letter dated July 6, 1984, the licensee requested exemptions from Sections III.G, III.J. and III.L of Appendix R.
By letters dated November 30, 1984, April 10, 1986, and October 16, 19d7, the licensee transmitted revisions to its Appendix R evaluation.
i
III.
The following list of exemptinn requests, therefore, reflects the latest status:
1.
Containment Incore Instrument Tunnels (Fire ~ Areas 15 and 16).
An exemption was requested from the specific requirement of Section III.G.2.d to the extent that less than 20 feet of separation exists between redundant excore neutron flux detector cables in these areas.
2.
Separation of Instrumentation Inside the Containrients (Fire Areas 15 and 16).
An exemption was requested from the specific requirement of Section III.G.2.d to the extent that intervening combustibles exist between redundant cables and equipment separated by 20 feet or by radiant energy shields.
3.
Emergency Lighting in the Containments, Main Control Room, and in Exterior Access Routes.
Exemptions were requested f*om the specific requirements of Section III.J to the extent that it requires 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> emergency lighting in all areas needed fcr operation of safe shutdown equioment and in access and egress routes thereto.
4 Refueling Water Storage Tank.
An exemption was requested from the specific requirement of Section III.L.2.d to the extent that process monitoring is not capable of providing direct readings of process variables necessary to perform and control required safe shutdown functions.
5.
Redundant Circuits in a Manhole Adjacent to Fuel Oil Pumphouse Room 2 (Fire Area 180.
t a
.A.
i An exemption was req'iested from the specific requirement of Section III.7,7.3 to the extent that cables of redundant trains are not separated hv a fire barrier having a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire resistance rating.
In summary, exemotions were requested from the requirements nf separating cables and associated nonsafety circuits n# redundant trains by 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire barriers as discussed in Section III.G.2.a of Appendix R, and from provid-ing horizontal separation of more than 20 feet with no intervening combustibles as required b.v Sections III.G.2.b and III.G.P.d.
In addition, exemptions were requested from the emergency lighting reouirenents o# Section III.J.
Also, an exemption was requested from the requirement of providing direct reading of process variables as discussed in Sectinn III.L.2.d.
The licensee has provided alternative and/or acceptable levels of fire oro-tection for areas containing redundant safe shutdown systems not separated from each other.
Fire orntection in areas containing more than the negligible com-bustible load and containing safe shutdown equipment or cables consists nf fire detectors, portable extinguishers, and hose stations.
As discussed in the staff's Safety Evaluation dated February 25, 1088, the staff concludes that the areas under consideration are expected to contain the minimum arrcunt of comoustible loading. Also, there are other features, such as separation between cables, installation of cables in rigid conduit and fire stop provide a reasonable assurance that a fire in these areas wnuld be o' low nagnitude, promptly detected, and extinguished.
Based on the staff's review of the licensee's analyses, the staff concludes that the level of fire protection provided is eouivalent to the technical requirements of Sections III.G, III.J, and III.L of Appendix R.
Additional details concerning the exemptions are prnvided in the Safety Evaluation dated February 25, 1988.
5-By letter dated September 30, 1986, the licensee provided information relevanttothe"shecialcircumstances"'indingrequiredbyrevised 10 CFR 50.12/a). The licensee stated that the analysis accompanying each exemo-tion request demonstrates that an acceptable level of fire protection already exists at Surry Power Station and the licensee has achieved the underlying pur-pose o' the requirements of the applicable sections of Appendix R.
In addition, the licensee stated that i# the exemptions are denied, it would be necessary to design and install modi'ications to provide additional fire detection and fire suppressinn systems, fire barriers, emergency lighting, and instrumentation.
Overall, these changes would require a significant expenditure of engineering, construction, and operations resources, as well as associated capital costs, which are not necessary to achieve underlying purpose o' the rule, and the modifications would not increase the overall level of protection 'or safe shut-down equipment.
The staff has reviewed the fire protection analysis for each of the exemp-tions renuested by the licensee and concludes that the existing and proposed fire protection features at Surry Power Station provide a level of safety equivalent to the technical requirements cf applicable sections of Appendix R.
Therefore, the staff concludt:s that "special circumstances" exist for the licensee's reouested exemptions in that application of the reoulation in these particular circumstances is not necessary to achieve the underlying purposes of Appendix R to 10 CFR 50.
See 10 CFD 50.12(a)(?)(ii).
The detailed evaluation of each of these exemption!. is provided in the staff's Safety Evaluation dated February 25, 1C88.
6-IV.
Accordingly, the Comission has determined, pursuant to 10 CFR 50.12(a),
that (1) the exemptions as described in Section III are authorized by law and will net present an undue risk to the public health and safety and are consistent with ccrrrren defense and security, and (?) special circurstarces are present for the exempticns in that application of the regulaticn in these parti-cular circur:starces is not recessary tc achieve the underlying purposes cf Appendix R tc 1C CFR 50.
Therefore, the Comission hereby grants the folicwing exenptions froc: the requirements of Sections III.C, III.J, and III.L cf Apperdix R to IC CFR 50:
1.
Containcent Incore Instrurrent Tunnels (Fire Areas 15 and 16) to the exter>t that the redundant excore neutren flux detector cables in these treas are nct separated by a horizontal distance of more than 20 feet pursuant to the requirements of Section III.G.2.d.
2.
Separation of Instrurnentation Inside the Containnents (Fire Areas 15 ard 16) to the extent that safe shutdown cables and equipment separated by 20 feet or by radiant energy shields are not free of intervening corrbustibles pursuant to Section III.G.2.d.
3.
Emergency Lighting in the Containtnents, Main Control Rocm, and Exterior Access Routes to the extent that F hour battery-powered emergency lighting is not provided pursuant to Section III.J.
4 Refueling Water Storage Tank to the extent that process inonitoring is not capable of providing direct readings of processed variables necessary to perform and control required safe shutdown functions pursuant to Section III.L.P.d.
2
> 5.
Redundant Circuits in a Manhole Ad.iacent to Fuel Oil Pumohouse Room 2 (Fire Area 18B) to the extent that cables of redundant trains are not separated by a fire barrier having a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire resistance ratino pursuant to Section III.G.2.a.
Pursuant to 10 CFR 51.32, the Comission has detennined that the granting of these exemotions will have no significant impact on the environment
(.Februa ry 25, 1988, 53 FR 56591, A copy of the Safety Evaluation dated FeEruary 25
, 1988, related to this action is available for oublic inspection at the Comission's Public Documnt Room,1717 If Street, NH, Washingtor., D.C., and at the Swen Library, College of William and Mary, Williamsburo, Virginia 23185.
A copy may be obtained upon written request addressed to the U.S. Nuclear Reculatory Comis-sion, Weshington, D.C.
20555, Attention:
Director, Division of Reactor Projects I/II.
These Exemotions are effective uoon issuance.
Dated at Reckville, Maryland this 25th day of Fehruary,1938, FOR THE NUCLEAR REGULATORY C0KMISSION O
even A.
,' hj c Division of Reactor Proj c 5 I/II Office of Nuclear Reacto egulation