ML20150E309
| ML20150E309 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 06/29/1988 |
| From: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8807150071 | |
| Download: ML20150E309 (2) | |
Text
1 I
.t VERMONT YANKEE NUCLEAR POWER CORPORATION RD 5. Box 169, Ferry Road, Brattleboro, VT 05301
,,, f o y
ENGINEERING OFFICE f
1671 WORCESTER ROAD FRAMING H AM. M ASS ACHUSETTS 01701 7 EL E PHONE 617-8 Tb6100 June 29, 1988 U.S. Nuclear Regulatory Commissien Washington, D.C.
20555 Attn:
Document Control Desk 4
References:
a)
License No. DPR-28 (Docket No. 50-271) b)
Letter, USNRC to VYNPC, NVY 88-054, dated 4/6/88 c)
Letter, USNRC to VYNPC, NVY 86-93, dated 4/24/86 d)
Lett r, VYNPC to USNRC, FVY 88-348, dated 5/6/88
Dear Sir:
Subject:
Request for Exemption - 10CFR, Part 50, Appendix R,Section III.J, "Emergency Lighting" In accordance with the provisions of 10CFR, Part 50.12, Vermont Yankee Nuclear Power Corporation hereby requests an exemption from the provisions of 10CFR 50, Apendix R,Section III.J, "Emergency Lighting," for the Reactor Building torus area of the Reactor Building.
BACKGROUND A recent inspection conducted by the Commission at Vermont Yankee (Reference b)] identified the northeast corner of the Reactor Building torus cat-walk area as an area where the requirements of 10CFR 50, Appendix R, Section III.J are not fully met, in that operation of safe shutdown equipment in this area is required as part of the Appendix R alternate shutdown scenario and emergency lighting is not provided.Section III.J requires that "Emergency lighting units with at least an eight-hour battery supply shall be provided in all arecs needed for operation of safe shutdown equipment and in access and egress routes thereto." By letter dated May 6, 1988 [ Reference d)], Vermont Yankee outlined its position relative to emergency lighting in the torus area of the Reactor Building, and committed to submit the subject exemption request.
JUSTIFICATION Vermont Yankee's Appendix R Alternate Shutdown System was designed to address a fire in the Control Room, Cable Vault, and Wert Switchgear Room.
l Alternate shutdown utilizes the Residual Heat Removal (RHR) System for torus l
cooling and shutdown cooling to help achieve cold shutdown.
In the event of a loss of Off-Site Power (LOOP), an Emergency Diesel Generator (EDG) i <: required to operate RHR. Although torus coo' ling is not required for several hi.' irs following a fire and LOOP, operation of an EDG is established by procedure early in the scenario. One of the advan % 2s cf bringing on the EDG is establishing emergency ac lighting.
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VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission June 29, 1988 Page 2 In order to ensure proper velve line ty) for RHR torus cooling, an operator is required by procedure to check that RHR-38A (suppression chamber spray valve) and RHR-66 (discharge to radwaste isolation valve) are closed.
These valves are located in the Reactor Building torus area off the catwalk.
This area, as well as access to the area, is provided with 120 V ac lighting backed by an EDG, Since torus enoling will not be established before a diesel generttor is opera-t ional, 120 V ac lighting will be available for operator actions u this aret.
Section 4 of Generic Letter 86-10, Reference c), states that the level of illumination provided by emergency lighting in access routes to and in areas where shutdown runctions must be performed be sufficient to enabic an operator to reach that area and perform the shutdown function.
The level of illumination provided by 120 V ac emergency lighting for an operator to gain access to and check closed Valves RHR-38A and RHR-66 has been field verified as being suf-ficient.
SPECIAL CIRCUMSTANCES 10CFR, Part 50.12, Section 2 (ii), states that a special circumstance exists when "application of the ".egulation of the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule." By providing 120 V ac emergency lighting for access routes to the Reactor Building torus araa and in the vicinity where RHR valves will be checked closed, Vermont Yankee aelieves that the underlying eur-pose of 10CFR, Part 50, Apper. dix R,Section II.T.J, is achieved.
The public health and safety is protected in a fashion equivcient to that resulting from compliance with the specific requirements of Section III.J of 10CFR 50, Appendix R.
CONCLUSION Based upon the technical justification and special circumstonces detailed above, Vermont Yankee requests an exemption from the requirements of 10CFR 50, Appendix R, Section III.J, Emergency Lighting, for the Reactor Building torus area.
We request an exoedited review of the subject exemption request, and have enclosed an application fee of $150.00 in accordance with the provisions of 10CFR 170.12.
We trust that our request is deemed acceptable; however, should you have any questions on this matter, please contact us.
Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION s(,ls..
+ry -
Warren P.
urphy d
Vice President and Manager of Operations
/dm cc:
USNRC Regional Administrator, Region I USNRC Resident Inspector, VYNPC