ML20155G571
| ML20155G571 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 06/07/1988 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20155G547 | List: |
| References | |
| NUDOCS 8806200022 | |
| Download: ML20155G571 (8) | |
Text
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7590-01 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of
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Docket Nos. 50-295
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and 50-304 COMMONWEALTH EDISON
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COMPANY Zion Nuclear Power
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Station, Units 1 and 2
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EXEMPTION I.
The Commonwealth Edison Company (CECO, the Licensee) is the holder of Operating License No. DPR-39 which authorizes operation of Zion Nuclear Power Station, Unit 1 and Operating License No. DPR-48 which authorizes operation of Unit 2.
The licenses provide, among rather things, that Zion Nuclear Power Station is subject to all rules, regulations, and Orders of the Commission now or hereafter in effect.
The Station is comprised of two pressurized water reactors at the Licensee's site located in Lake County, Illinois.
II.
On November 19, 1980, the Connission published a revised Section 50.48 and a new Appendix R to 10 CFR Part 50 regati ng fire protection features of nuclear power plants. The revised Section 50.48 and Appendix R became effective on February 17, 1981.
Section Ill of Appendix R contains 15 subsections, lettered A through 0, each of which specified requirements for a particular asget of the fire protect ion features at a nuclear power plant, l
l Two of these subsections, 'il.G c a III.0, are the subject of the Licensee's exemption requests.
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Subsection III.G.2 of Appendix R requires that one train of cables and equipment necessary 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-hour rating.
Structural steel forming a part of or supporting such fire barrt rs shall be protected to provide fire resistance equivalent to that required of the barrier, 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 areas.
Enclosure of cable and equipment and associated nonsefety circuits c.
of one redundant train in a fire barrier having a 1-hour 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 for areas where alternative or dedicated shutdown is provided, fire detection end a fixed fire suppression system shall also be installed in the area, room, or zone under consideration.
'III.
By letter dated July 27, 1984, the Licensee requested exemptions from specific requirements of Appendix R.
The Licensee provided additional l
informatier, in support of the staff's review of these requests in a letter I
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dated February 18, 1986.
By letters dated February 9,1987, January 21 and February 23, 1988, the Licensee provided additional information and modified its request of July 27, 1904 t>y withdrawing three of the exemption requests.
The remaining exempticr requests are the subject of this evaluation.
The following list reflects the latest status of exemptions requested:
1.
Main Control Room (Fire Zone 2.0-0).
An exemption was requested from the specific requirement of Section III.G.3 to the extent that an automatic fire suapression system is not provided throughout the zone.
2.
Auxiliary Electric Equipment Rooms (Fire Areas 5.6-1 and 5.6-2).
An exemption was requested from the specific requirement of Section III.C.3 to the extent that an automatic fire suppression system is not provided throughout each area.
3.
Auxiliary Building, Component Cooling Water (CCW) Pump Area.
Elevation 560 Feet.
An exemption was requested from the specific requirement of Section III.G.2.b to the extent that 20 feet of separation between redundant safe shutdown components and automatic suppression and detection systems are not provided.
4.
Auxiliary Building Elevations 592, 617, and 642 Feet.
An exemption was requested from the specific requirements of Section III.G.2.b to the extent that area-wide automatic suppression and detection systems and 20 feet of separation between redundant safe shutdown components do not exist.
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5.
Msin Steam Pipe Tunnels (Fire Zones 18.5-1 and 18.5-2).
Exemptions were requested from the requirements of Sectic.. III.G.2.b to the extent that it requires automatic suppression and detection systems throughout the main steam pipe tunneh.
6.
Auxiliary Building, Auxiliary Feedwater Pump Area, Elevation 579 Feet.
An exemption was requested from the requirements of Section III.G.2 to the extent that it requires area-wide automatic suppression and detection systems and 20 feet of separation between redundant safe shutdown components (the motor driven and turbine driven auxiliary feedwater pumps) for Fire Zone 11.3-0 at the 579 foot elevation of the auxiliary building fire area.
In sumary, the exemptions were requested from providing 20 feet of spatial separation, area-wide fire detection, and an automatic fire suppression system as required by Section III.G of Appendix R.
The Licensee has provided alternative shutdown capability for Fire Zone 2.0-0 (main control room).
The zone has a fire detaction system installed on an area-wide basis and is continuously manned.
Also, there are fire extinguishers and a hose station available for manual fire fighting purposes.
The expected fire in this zone would not threaten adjacent safe shutdown areas.
Alternative shutdown capability is provided for the auxiliary electric equipment rooms (Fire Areas 5.6-1 and 5.6-2).
These fire areas have an j
area-wide fire detection system, fire extinguishers, and hose stations for manual fire fightir.g. The combustibles consist primarily of cable insulation.
If a fire were to occurs it is expe n ed that it would develop slowly with initial low heat release and slow rise in room temperature.
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Redundant safe shutdown cables on auxiliary building elevations 592, 617, and 642 feet are provided with a minimum of 20 feet without intervening combustibles.
Ionization smoke detectors are provided in the areas of and between these cables on each elevation.
The Licensee has provided alternate steam generator pressure indication for Fire Zones 18.5-1 and 18.5-2.
The fuel load in these zones is low with significant spatial sep3 ration between redundant pressure transmitters.
The expected fire in these zones would not threaten other safe shutdown areas adjacent to them.
The Licensee has provided alternative and/or acceptable levels of fire protection for these areas which contain redundant safe shutdown systems not separated from each other in accordance with Section III.G of Appendix R.
Fire protection in these areas which contain more than a negligible combustible load and contain safe shutdown equipment or cables, consist of fire detectors and/or automatic fire suppression systems, and portable extinguishers and hose stations.
The staff finds that there is reasonable assurance that a fire in these areas would be of low magnitude, promptly detected, and extinguished.
% sed on the staff's review of the Licensees's analysis, the staff concludes that the installation of automatic fire suppression and/or detection systems throughout the Main Control Room (Fire Zone 2.0-0), Main Steam Pipe Tunnels (Fire Zones 18.5-1 and 18.5-2 Auxiliary Electric Rooms) (Fire Areas 5.6-1 and 5.6-2), and Elevations 560 feet, 579 feet, 592 feet, 617 feet and W
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642 feet of the Auxiliary Building would not significantly increase the level of fire protection of these zones. Additional details concerning the exemptions are provided in the Safety Evaluation issued concurrently.
By letter dated October 30, 1987, the Licensee provided information relevant to the "special circumstances" finding required by revised 10 CFR 50.12(a) (see 50 FR 50764). The Licensee stated that existing and proposed fire protection features at Zion Units 1 and 2 provided an equivalent level of fire protection required by Appendix R and therefore accomplished the underlying purpose of the rule.
Implementing additional modifications to provide additional suppression systems, detection systems, and fire barriers would require the expenditure of engineering and construction resources as well as the associated capital costs which would represent an unwarranted burden on th' Licensee's resources. The Licensee had estimated that the e
costs to be incurred would be.n excess of several million dollars. The Licensee stated that these costs are significantly in excess of those required to meet the underlying purpose of the rule.
The staff concludes that "special circumstances" exist for the Licensee's requested exemptions in that application of the regulation in these particular circumstances is not necessary to achieve the underlying purposes of Appendix R to 10 CFR Part 50. See 10 CFR 50.12(a)(2)(11).
Accordingly, The Comission has determined, pursuant to 10 CFR 50.12(a),
that (1) these exemptions as described in Section III are authorized by law l
and will not present an undue risk to the public health and safety and are
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consistent with common defense and security, and (2) special circumstances are present for the exemptions in that application of the regulation in these particular circumstances is not necessary to achieve the underlying purposes of Appendix R to 10 CFR Part 50. Therefore, the Commission hereby grants the following exemptions from the requirements of Section III.G of Appendix R to 10 CFR Part 50:
1.
Main Control Room (Fire Zone 2.0-0) to the extent that there is no q
fixed fire suppression system installed pui3uant to Section III.G.3.
2.
Auxiliary Eleatric Equipment Rooms (Fire Areas 5.6-1 and 5.6-2) to the extent that there is no fixed fire suppression system installed pursuant to Section III.G.3.
3.
Auxiliary Building, Component Cooling Water (CCW) Pump Area, Elevation 560 Feet to the extent that automatic fire suppression and detection systems are not installed and 20 feet of separation is not provided pursuant to Section III.G.2.b.
4.
Auxiliary Building, Elevations 592, 617, and 642 Feet to the extent that automatic fire suppression and detection systems are not installed throughout the area pursuant to Section III.G.2.b.
5.
Main Steam Pipe Tunnels (Fire Zones 18.5-1 and 18.5-2) to the extent that automatic fire suppression and fire detection systems are not installed throughout the area pursuant to Section III.G.2.b.
6.
Auxiliary Building, Auxiliary Feedwater Dump Area, Elevation 579 Feet to the extent that automatic fire suppression and detection 0
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systems are not installed throughout the area and 20 feet of separation is not provided between redundant safe shutdown components pursuant to Section III.G.2.
1 Pursuant to 10 CFR 51.32, the Comission has determined that the granting of these exemptions will have no significant impact on the environment (52FR42046).
A copy of the Safety Evaluation, related to this action, is available for public inspection at the Comission's Public Document Room,1717 H Street, l
N.W., Washington, D.C. and at the local public document room located at the Waukegan Public Library, 128 N. County Street, Waukegan, Illinois 60085.
This Exemption is effective upon issuance.
1 FOR THE NUCLEAR REGULATORY COMMISSION
'?M. &
Dennis M. Crutchfield, D ector Division of Reactor Pr cts - III, IV, Y and Special Projects Office of Nuclear Reactor Regulation Dated at Rockville, Maryland this 7th day of June 1988 4
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