ML20197G440
| ML20197G440 | |
| Person / Time | |
|---|---|
| Site: | Point Beach, San Onofre  |
| Issue date: | 05/09/1986 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | Harold Denton, Lear G Office of Nuclear Reactor Regulation |
| References | |
| CON-NRC-86-42 VPNPD-86-213, NUDOCS 8605160217 | |
| Download: ML20197G440 (2) | |
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MSC00 Sin Electnc ma cower 231 W. MICHIGAN, P.O. BOX 2046, MILWAUKEE,WI 53201 (414)277-2345 VPNPD-86-213 NRC-86-42 May 9, 1986 Mr. Harold R.
Denton, Director Office of Nuclear Reactor Regulation U.
S.
NUCLEAR REGULATORY COMMISSION Washington, D.C.
20555 Attention:
Mr. George Lear, Director PWR Project Directorate #1 Gentlemen:
DOCKET NOS. 50-266 AND 50-301 10 CFR 50 APPENDIX R EXEMPTION REQUESTS POINT BEACH NUCLEAR PLANT UNITS 1 AND 2 By letters dated April 28 and October 26, 1983, as supplemented in a letter dated December 11, 1985, Wisconsin Electric Power Company requested, pursuant to 10 CFR 50.12, exemptions from certain requirements of 10 CFR 50 Appendix R,
" Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1,
1979," for our Point Beach Nuclear Plant Units 1 and 2.
In a letter dated July 3, 1985, the NRC granted several of these exemption requests and stated that the remaining requests were still under staff review.
The exemption requests which had not been addressed concerned provisions for the service water pump room, the residual heat removal pump zones, and the auxiliary building fire area.
Subsequent to our submittals of information regarding these exemption requests, the Commission published a change to its rules at 10 CFR 50.12 " Specific Exemptions."
This rule change became effective on January 13, 1986, and states that the Commission will not consider granting an exemption unless special circumstances are present.
The revised rule identifies six cate-gories of special circumstances.
We were recently advised by Mr. Colburn of your staff that the Commission has determined that all outstanding exemption requests, including those filed prior to the recent 10 CFR 50.12 rule change, must address these special circumstances.
It is our 8605160217 860509 i
PDR ADOCK 05000206 00Y F
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s3 Mr. Harold R. Denton May 9, 1986 Page 2 understanding that the outstanding exemption requests for the Point Beach Nuclear Plant mentioned previously in this letter have been evaluated and are ready to be issued pending only sub-mission of these special circumstances.
Paragraph (a)(2)(ii) of the revised 10 CFR 50.12 states that special circumstances are present whenever, " Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule."
The information submitted with our exemption requests, as previously referenced, provides well supported documentation to establish that the application of this special circumstance to these exemptions is appropriate.
For example, page 6-15 of the " Final Report - Response to 10 CFR 50 Appendix R ' Alternate Shutdown Capability'" as enclosed with our October 26, 1983 letter states, in reference to the Auxiliary Building Fire Area Exemption Request, "The exemption is requested on the basis that the post-modification fire protection features provide suitable protection for required' safe shutdown cables and equipment and that additional modifications would not enhance fire protection or safe shutdown capability in the Point Beach Auxiliary Building, above that provided by proposed modifications and existing features."
Similarly, pages 6-11 and 6-12 of the above reference conclude that although the existing fire protec-l tion features provided for the residual heat removal pump zone do not constitute verbatim compliance with Section III.G.2 of the 10 CFR 50 Appendix R rule, addition of automatic suppression in that fire zone would not enhance fire protection above that which already exists.
The discussions regarding the Service Water Pump Room also support this special circumstance.
i We therefore conclude that the information previously submitted to the NRC in our letters dated April 28 and October 26, 1983 and December 11, 1985 provide adequate information to establish that the special circumstance contemplated in 10 CFR 50 Paragraph (a)(2)(ii) is present for these exemption requests.
Accordingly, we request that the decision on these exemption requests be issued forthwith.
Very truly yours,
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( hL C.
W.
Fay Vice President Nuclear Power Copy to NRC Resident Inspector l
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