ML20205F188

Provides Info Re Special Circumstances Finding Required by 10CFR50.12(2) to Enable Previously Filed Requests for Exemptions from 10CFR50,App R to Be Considered.Special Circumstance within Acceptable Level of Fire Protection

ML20205F188
Person / Time
Site:	Vermont Yankee
Issue date:	08/15/1986
From:	Capstick R VERMONT YANKEE NUCLEAR POWER CORP.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
FVY-86-74, NUDOCS 8608190111
Download: ML20205F188 (3)

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VERMONT YANKEE NUCLEAR POWER CORPORATION

. RD 5 Box 169, Ferry Road, Brattleboro, VT 05?01 ,,,Ly 7, y ENGINEERING OFFICE 1671 WORCESTER ROAD

• FRAMINGHAM, MASSACHUSETTS 01701

• T ELEPHONE 6174724100 August 15, 1986 FVY 86-74 United States Nuclear Regulatory Commission Washington, DC 20555 Attention: Harold R. Denton, Director Office of Nuclear Reactor Regulation

References:

(a) License No. DPR-28 (Docket No. 50-271)

- (b) Letter, VYNPC to USNRC, FVY 84-24, dated March 14 1984 (c) Letter, VYNPC to USNRC, FVY 84-49, dated May 21, 1984 (d) Letter, VYNPC to USNRC, FVY 84-85, dated July 10, 1984 (e) Letter, VYNPC to USNRC, FVY 84-109, dated September 12, 1984 (f) Letter, VYNPC to USNRC, FVY 85-38, dated April 24, 1985 (g) Letter, VYNPC to USNRC, FVY 85-73, dated August 16, 1985 (h) 50 Federal Register 50764, dated December 12, 1985

Subject:

Request for Exemptions from the Requirements of 10CFR, Part 50, Appendix R: "Special Circumstances"

Dear Sir:

l l By letter, dated April 24, 1985 [ Reference (f)}, as supplemented by l letter, dated August 16, 1985 [ Reference (g)], Vermont Yankee requested 11 l exemptions from the provisions of Section III.G of Appendix R. The exemptions address four plant areas which, per Appendix R, require physical separation and/or fire protection systems to protect redundant trains of safe shutdown-related cable and equipment. The April 24, 1985 letter superseded l

Vermont Yankee's letters, dated March 14, 1984, May 21, 1984, July 10, 1984, l and September 12, 1984 [ References (b) through (e)). Subsequently, the NRC l amended its regulations to clarify the standards that will be applied when it l considers the granting of exemptions from the requirements codified in 10CFR, l Part 50 [ Reference (h)]. As a result, your staff has informed us that specific information relevant to the "special circumstances" finding required by the revised 10CFR50.12(a) must be submitted in order for our previously filed exemptions requests to be considered. Accordingly, Vermont Yankee herein provides the required information.

i Section 50.12(a)(2) of the final rule provides that the Commission will l

l not consider granting an exemption unless special circumstances are present.

l One of special circumstances specified in the rule is 50.12(a)(2)(ii) which o

b 9608190111 860815 PDR ADOCK 0500 h0 gD F

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United States Nuclear Regulatory Commission August 15, 1986 Attention: Harold R. Denton Page 2 states, " 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." As established in Vermont Yankee's submittals of April 24, 1985 and August 16, 1985 [ References (f) and (g)], the existing and proposed fire protection features associated with the referred exemption requests accomplish the underlying purpose of Section III.G.2 of 10CFR50, Appendix R to the extent that redundant trains of safe shutdown-related cable and equipment are protected in the event of a fire.

Therefore, Vermont Yankee believes that a special circumstance pertaining to these exemption requests applies wherein an acceptable level of fire protection exists which is equivalent to that required by Section III.G.2 of the rule.

Another of the special circumstances identified in 50FR50776 for which the Commission believes it would be reasonable to grant an exemption is

"(111) Compliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted or that are significantly in excess of those incurred by others similarly situated." Vermont Yankee believes that existing and proposed fire protection features at Vermont Yankee accomplish the underlying purpose of the rule and that 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, representing an unwarranted burden on Vermont Yank 2e's resources. The costs to be incurred are as follows:

o Engineering and installation of additional piping, sprinkler heads, and supporting structures.

o Engineering and installation of fire barriers, supports, support protection, and ongoing maintenance.

o Rerouting of power and control cables, and associated conduits, and supports.

o Increased surveillance on aew or extended fire suppression and fire detection systems, o Increased congestion in numerous plant locations complicating future plant modifications / operation.

Because these costs are significantly in excess of those required to meet the underlying purpose of the rule, Vermont Yankee has determined that "special circumstances" exist for the requested exemptions in that application of the regulation in these particular circumstances is not necessary to achieve the underlying purposes of Appendix R to 10CFR, Part 50. Therefore, Vermont Yankee requests approval of the referenced exemption requests.

United States Nuclear Regulatory Conunission August 15, 1986 Attention: Harold R. Denton Page 3 We trust the above information is acceptable; however, should you have any questions, or require additional information, please contact this office.

Very truly yours, VERMONT YANKEE NUpL POWER CORPORATION SW $

R.W.Capftick Licensing Engineer RWC/no i

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