ML20207K084
| ML20207K084 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/30/1986 |
| From: | Schroeder F Office of Nuclear Reactor Regulation |
| To: | GENERAL PUBLIC UTILITIES CORP. |
| Shared Package | |
| ML20207K087 | List: |
| References | |
| NUDOCS 8701090226 | |
| Download: ML20207K084 (21) | |
Text
.
7590-01 UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
GENERAL PUBLIC UTILITIES NUCLEAP
)
DocketNo.50-28hl CORPORATION, ET AL.
)
)
j (Three File Island Nuclear
)
Station. Unit No. 1)
)
1 EXEMPTION 1.
i General Public Utilities Nuclear (GPUN) Corporation (the licensee) and three co-owners hold Facility Operating License No. DPP-50, which authorizes operation of the Three Mile Island Nuclear Station, Unit No. 1 (TMI-1) (the facility) at power levels not in excess of 2535 megawatts thermal. This i
license provides, among other things, that the facility is sub.iect to all rules, regulations, and Orders of the Nuclear Regulatory Commission (the Commission or the staff) now or hereafter in effect.
The facility is a pressurized water reactor located at the licensee's site in Dauphin County, Pennsylvania.
4 4
II.
4 10 CFR 50.48, " Fire Protection," and Appendix'R to 10 CFR Part 50, " Fire Protection Procram for Nuclear Power Facilities Operating Prior tn January 1, 1979" set forth certain fire protection features required to satisfy the General Design Criterion related to fire protection (Criterion 3, Appendix A to 10 CFR 50).
l t
Section III.G of Appendix P requires fire protection for equipment important to safe shutdown. Such fire protection is achieved by various I
combinations of fire barriers, fire suppression systems, fire detectors, and i
j 8701090226 861230 4
PDR ADOOK 05000289 F
PDR i
separation of safety trains (III.G.2) or alternate safe shutdown equipment free of the fire area (III.G.3). The obiective of this protection is to assurethatonetrainofequipmentneededforhotshutdownwouldh[ undamaged by fire, and that systems needed for cold shutdown could be repaired.within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (III.G.li.
Section III.J of Appendix P requires emergency liahting units with at least an eight-hour battery power supply be provided in all areas needed for operation of safe shutdown eauipment and in access and egress routes thereto.
I III.
By letters dated October 30, 1984, February 11, 1985, November 7, 1985, May 17, 1986, July 22, 1986, August 19, 1986, October 22, 1986, and l
November 20, 1986, the licensee provided details of their fire protection program and requested approval of a number of exemptions from the technical requirements of Sections III.G and III.J of Appendix R to 10 CFR 50.
In subsequent correspondence dated July 22, 1986, and November 19, 1986, the licensee withdrew several of the previously requested exemptions. The Commission is denying some of the requested exemptions as set forth in its concurrently issued Safety Evaluation. A description of the remaining exemption requests and a summary of the Commission's evaluation follow.
I 1.
III.G.2; exemption requested from installing automatic fire detection in area FH-FZ-2 (Fuel Handling Building at elevation 305 feet): The staff's principal conuri. with the level of protection in this area was that a fire might propagate undetected and damage redundant, shutdown-related systems.
However, the locations within the area which contain nost of the combustible material and in which transient combustibles would most likely be found are
i -
i protected by an automatic fire suppression system.
If a fire of significant magnitude were to occur, the staff expects the suppression system to actuate.
This would cause an alarm to be visually and audibly annunciated infthe 4
]
control room. The fire brigade would be subsequently dispatched and would complete fire extinguishment using manual fire fighting equipment. Pending actuation of the suppression system and the arrival of the brigade, a fire barrier would provide adequate passive protection to one division of shutdown-I l
related cables.
For those cables which have not been physically separated or i
j protected, the licensee has stated that sufficient time is available to manually i
operate valves to reestablish flow paths (see Exemption 2). These manual actions i
would be taken in areas that are isolated from the effects of a fire either by i
physical barriers or by automatic fire suppression systems. On this basis, the staff concludes that the licensee's alternate fire protection configuration represents an equivalent level of fire safety to that achieved by compliance t
with Section III.G.2.
The special circumstances of 10 CFR 50.12 apply in that application of the regulation in tne particular circumstances is not necessary to achieve the underlying purpose of the rule. The regulations require the installation of an automatic fire detection system to warn operators of a fire so that
]
appropriate corrective action can be taken. The area of concern contains an automatic fire suppression system. A fire of sufficient magnitude would cause i
the fire suppression system to actuate which would in turn sound an alarm.
Thus, the underlying purpose nf the rule would be satisfied without installina i
an automatic fire detection system.
2.
III.G.2; exemption requested to allow manual operation of certain valves and pumps in lieu of providing fire protection: The licensee identified 1
a number of areas in which redundant cables and components associsted with letdown valves, makeup valves, steam dump valves, steam supply valves, emergency feedwater valves, and the intermediate cooling water and nuclear service cooling water pumps are not protected per the fire protection options identified in Section III.G.2. The licensee states that if a fire damages these cables, sufficient time exists to manually align the valves and to manually control the pumps so as to achieve and maintain safe shutdown conditions. The time periods within which the licensee must accomplish these actions vary from 20 minutes for certain emergency feedwater system valves to 240 minutes for certain valves in the makeup system. The minimum time frame to establish local control of the intermediate cooling water pumps and the nuclear service cooling water pumps is 30 minutes.
The technical requirements of Appendix R are not met in the subiect areas because cables and components for certain shutdown-related valves and pumps are not provided'with fire protection in accordance with.the options identified in Section III.G.
The staff has several concerns regarding the reliance on manual actions in lieu of physical protection of shutdown systems. The first is that plant i
operators may have to enter the fire area before it is reasonable to expect that habitable conditions may be restored after the fire. The licensee, in the July 22, 1986 submittal, identified a number of locations where safe shutdown can only be achieved by reentering the fire area to assure proper valve alignment. However, in no instance is it necessary to enter these
areas before two hours after fire damage occurs. Although it is not possible to predict the nature and duration of a fire in any location, the s,taff expects that within one hour a fire would have been detected and controlle and near ambient conditions restored. This conclusion is based on the description of plant hazards and available protection as provided by the licensee in Revision 7 of the Fire Hazards Analysis Report (FHAR). The licensee's analyses indicated that an additional hour exists beyond the staff's assumptions. This results in a sufficient margin of safety to piovide reasonable assurance that manual actions within the fire area can be achieved.
The staff was also concerned that fire damage to valve operators would prevent manual valve alignment. However, the licensee responded to this concern by stating, in the July 22, 1986 letter, that fire damaoe to valve operators will not prevent the valve operators from being manually turned.
r A further staff concern is that because not all fire areas are physically separated from ad,ioining locations by continuous fire-rated construction, fire propagation through non-rated boundaries might prevent operators from performing manual operations. However, where fire area boundaries are not completely fire-rated, the licensee indicates that 1) the areas on one or both sides of the boundary are protectod by an automatic fire suppression system, or 2) the boundary wall or floor / ceiling forms a continuous non-combustible barrier to the propogation of fire, or 3) the adjoining area into which fire may spread is not relied upon for safe shutdown.
An additional concern is that the post-fire shutdown procedures and available personnel are adequate for the tasks to be performed. The licensee responded that procedures will be prepared in conformance with staff fire
, protection guidance as provided in Generic Letters 81-12 and 86-10. The staff considers this response acceptable. However, the adequacy of these procedures will be confirmed during the Appendix R inspection.
O The staff's remaining concern is that the manual actions required in locations outside the fire area could actually be accomplished within the maximum available time period stipulated by the licensee while a plant fire was underway. As previously stated, these time limits range from 20 minutes to 240 minutes.
It is not possible to predict the nature of a fire event or the actions of plant operators during an emergency. However, the staff expects that a degree of uncertainty and confusion will exist and that time delays will occur in the implementation of manual actions.
It is the staff's
,iudgment that where manual actions, includino valve alignment and pump control, are required less than 30 minutes after initial fire damage, an insufficient margin of safety exists to provide reasonable assurance that safe shutdown can be achieved and maintained.
For those actions which must be taken beyond 30 minutes, the staff concludes that manual actions can be expected to be completed before an unrecoverable plant condition occurs.
For'those valves where manual action can be taken beyond 30 minutes, the staff concludes that the licensee's proposal represents an equivalent level of safety to that achieved by compliance with III.G.2.
The special circumstances of 10 CFR 50.12 apply in that application of the regulation in the particular circumstances is not necessary to achieve the underlying purpose of the rule. The underlying purpose of the rule is to accomplish safe shutdown in the event of a single fire and maintain the plant in a safe condition. The rule requires fire protection for circuits and components associated with shutdown-related valves and pumps. However, certain
valves and pump controllers can withstand the effect of a fire and still be manually operated. Sufficient time exists to allow this manual ope, ration and maintain the plant in a safe shutdown condition. Thus, the underlykna purpose of the rule is satisfied allowing manual operation of these components.
Additionally, the licensee argues that providing additional protection features, as required by the regulations, would not result in a sionificant increase in the level of protection provided and would result in undue hardship and costs significantly in excess of those incurred by others similarly situated. These costs consist of additional engineering, procurement of materials, fabrication, and installation costs.
3.
III.G.2; exemption requested to allow use of fire-rated cable in lieu of a fire barrier around certain shutdown-related circuits in the following areas: AB-FZ 4 (Penetration Area), ISPH-FZ-1 (Intake Screen Pumphouse), ISPH-FZ-2 (Intake Screen Pumphouse), and FH-FZ-1 (Fuel Handlina Building Area): The technical requirements of Section III.G are not met in Areas AB-FZ-4, ISPH-FZ-1, ISPH-FZ-2, and FH-FZ-1 because certain shutdown-related cables delineated in the licensee's Revision 7 of the FHAR and May 17, 1986 letter are not protected by a one-hour fire-rated barrier and would not be free of damage after being subjected to a fire.
The staff's concerns with the use of the fire-rated cable outside of containment are as follows:
(a) Functional Capability The staff was concerned that the cable would not perform its intended function when exposed to the effects of a fire.
In response, by letter dated June 9,1984, the licensee submitted the results of a fire test conducted by
1 -
Underwriter's Laboratories, Incorporated.
Representative samples of the cable were subjected to a one-hour fire endurance and hose stream test in:accordance with the method in ASTM E-119. During the fire test and for a pert d of 93 hours0.00108 days <br />0.0258 hours <br />1.537698e-4 weeks <br />3.53865e-5 months <br /> beyond, electrical measurements were taken to confirm the cable's electrical
]
performance. The results confirm that the acceptance criteria of ASTM E-119 were met or exceeded. The staff, therefore, has reasonable assurance that the 1
cables will function as designed until the fire is extinguished.
(b) Mechanical Damage The staff was concerned that the heat produced in a fire would cause structural features such as cable trays to collapse. The falling debris might impact the cable and cause its failure.
In response, the licensee indicated that the four areas of concern are protected by a complete fire detection system that alarms in the control room.
If a fire should occur, it would be detected in its formative stages before significant temperature rise occurs.
The fire brigade would then extinguish the fire using manual fire fighting equipment. Additionally, if rapid fire propagation occurred, the available automatic sprinkler systems would actuate to suppress the fire and reduce room temperatures and thereby protect the shutdown-related cable and prevent debris formation. The staff, therefore, has reasonable assurance that the " fire-rated" cable will not be mechanically damaged by falling debris during a fire.
(c) Hiaher Temperatures in Cable Trays l
In the proposed application, the " fire-rated" cable would be routed, in 1
part, through cable trays containing conventional cable. The staff was concerned that a fire involving such cable would be more severe than the ASTM E-119 time-
temperature curve. The fire test previously discussed included a configuration containing conventional cable, and since satisfactory results were pbtained, this concern is resolved.
(d) Applicable Cable Voltaces In the early fire tests, the conductors of the " fire-rated" cable were energized at 110 Vac. The staff was concerned that the cable would be used at higher voltages (e.g. 600V). Subseauent fire tests were performed with the conductors energized at 480 Vac and 960 Vac and satisfactory results achieved.
Therefore, this concern has been resolved.
(e) Changes in Electrical Characteristics The staff was concerned that the " fire-rated" cable would not provide the electrical performance characteristics that are necessary for successful j
operation in the various applications.
For example, the " fire-rated" cable is proposed for power, control and instrumentation circuits. The electrical characteristics of the cable (i.e. conductor and insulation) will change with temperature increase. Thus, the insulation must be designed and the cable must be sized so that these changes do not affect the performance of the required function. The electrical performance criteria for each application (i.e. power, control or instrumentation) must be specified.
The " fire-rated" cable must then be shown to meet these criteria to assure that changes in the electrical characteristics of the " fire-rated" cable during a fire will not affect circuit operation.
In response, electrical performance criteria were provided in Section 3.0 of the FHAR. The staff concludes this response is acceptable.
i
i.
(f) Post-Fire Operability Because the fire-rated cable could be damaged by a fire, the staff was originally concerned that this damage would effect long-term performance of shutdown functions following a fire. However,-because the licensee will install the cables outside of containment in areas completely protected by automatic fire detection and suppression systems, the staff concludes that any damage would be negligible and should not affect performance.
(g)
Immersion Resistance The staff was concerned that " wet short" conditions were not simulated in the " fire-rated" cable tests but cables in cable trays may be immersed in water for a significant time. The exemption request included only stainless steel sheathed cables and unsheathed cables in conduit. The staff concludes that such cables would not be subject to failure by " wet shorts," and this concern is considered resolved.
(h) Thermal Expansion Forces The staff was concerned that thermal expansion forces and post-fire mechanical forces due to firefighting and recovery operations were not simulated. The licensee indicated, however, that for the distributed fire load in this area, a real fire would not result in temperatures approaching the ASTM E-119 time-temperature curve over a large portion of the fire area even if the automatic suppression system did not operate.
Prompt action by the fire brigade and automatic suppression would further reduce the time-temperature curve. The staff, therefore, concludes that satisfactory results from the hose stream tests with repeated application of hose stream forces have resolved this concern.
(i) Post-Test Assessment of Operability The staff was concerned that no post-test assessment of the operability of the " fire-rated" cables had been made.
Subseauent tests have sH wn that the " fire-rated" cable can remain functional during the fire and for at least 94 hours0.00109 days <br />0.0261 hours <br />1.554233e-4 weeks <br />3.5767e-5 months <br /> thereafter. Therefore, this concern is resolved.
(j) Mechanical Damage Due to Delay in Automatic Suppression The staff was concerned that if the automatic suppression system did not operate as designed for a rapidly developing fire, the " fire-rated" cable could be damaged by debris. In the staff's opinion, the probability of a severe, rapidly developing fire is low with the in-situ final configuration, and the cable would not be damaged even if automatic suppression was delayed. Therefore, this concern is resolved.
(k) Continuous Cable in Each Fire Area The " fire-rated" cable should be continuous through the fire ares (i.e.,
splices between " fire-rated" and non " fire-rated" cable should be made outside of the fire area boundaries).
In the November 7, 1985 revision to the FHAR, the licensee stated that the "Rockbestos" cable will generally be continuous.
Where joining within the fire area is required, the splices will be enclosed in terminal boxes protected by a one-hour fire barrier. On this-basis, this concern is considered resolved.
(1) Long-Term Surveillance The staff was concerned that for the life of the plant there would be no surveillance of the fire-rated cable comparable to that provided for fire-rated barriers. However, by letter dated July 22, 1986, the licensee committed to visually inspect the cable to verify its integrity whenever work is conducted
I j
a in the vicinity of the cable. The plant maintenance procedures which will be modified to incorporate this requirement were listed in the letter. On this basis, the staff considers this concern resolved.
Based on the above evaluation, the staff concludes that the use of
" fire-rated" cable in a fire area with a distributed in-situ fire loading and protected by automatic suppression systems provides an equivalent level of safety to that achieved by installing a one-hour fire barrier per Section III.G.2.C of Appendix R.
The special circumstances of 10 CFR 50.12 apply in that application of the regulation in the particular circumstances is not necessary to achieve the underlying purpose of the rule. The rule requires that redundant shutdown related systems be separated by a one hour fire-rated barrier and be free of fire damage. The underlying purpose of the rule is to accomplish safe shutdown in the event of a single fire and maintain the plant in a safe condition.
This is accomplished by assuring that sufficient undamaged equipment is i
available to support safe shutdown assuming a fire within the area of concern.
The use of fire-rated cable in a fire area with a distributed in-situ fire loading and protected by automatic suppression systems assures that the equipment involved will be available to accomplish its safe shutdown function in the event of a fire. Thus, the underlying purpose of the rule is achieved.
4.
III.G.2; exemption requested to allow less than 20 feet of separation which is free of intervening combustibles between redundant shutdown systems in area AB-FZ-4 (Penetration Area): The specific concern for a fire in this area is failure of the reactor coolant pump seals due to loss
.. of both seal injection and thermal barrier coolina. Protection of either is sufficient to assure safe shutdown.
In the June 4, 198a Safety Eva,1uation, the staff granted an exemption in this area from the requirement t protect the required shutdown systems on the basis that sufficient time existed to perform manual-actions to compensate for fire damage and provide adequate seal injection. However, by letter dated May 17, 1986, the licensee identified a shutdown scenario in which the time available for manual operation of valve MU-V14A (for seal injection) is " unacceptably short."
Therefore, in order to assure reactor coolant pump seal integrity, the licensee reevaluated the availability of either seal injection through MU-V14A or thermal barrier cooling through IC-V3 for a fire in the area. The licensee concludes that one of these paths will be free of fire damage in order to ensure safe shutdown.
Protection of the cables for the above referenced valve operators in this fire area will be achieved using "Rockbestos" fire-rated cable. Despite these modifications, the valve operators for MU-V14A and its redundant counterpart, IC-V3, will not have a fire barrier between them. These valves are separated by a line-of-sight distance in excess of 33 feet.
The technical requirements of Section III.G.2 have not been met for the above referenced valves because even though the valve operators are separated by more than 33 feet, the intervening space contains combustible materials in the form of cables in trays.
The staff was concerned that in the event of a fire both valve operators would be damaged. However, the fire hazard between these valves consists of cable insulation. A fire involving cable insulation would
. initially burn slowly with much smoke but with low heat release. The staff expects the existing fire detection system to actuate during the formative stages of the fire before serious damage would result. The fire b gade would be dispatched and would put out the fire using manual fire fiohting eouipment.
If the fire spread rapidly and a significant temperature rise occurred, the automatic sprinkler system would actuate to control the fire and to protect the valve actuators. Pending actuation of the system and/or arrival of the brigade, the horizontal distance between the valves provides reasonable assurance that no more than one valve would be damaged in the fire. Therefore, the presence of combustible materials in the intervening space between the valves is not significant.
Based on the plant conditions as described above, the staff concludes that the licensee's alternate fire protection configuration represents an equivalent level of safety to that achieved by compliance with Section III.G.2.
The special circumstances of 10 CFR 50.12 apply in that application of the regulation in the particular circumstances is not necessary to achieve the underlying purpose of the rule. The rule requires that redundant shutdown related systems be separated by more than 20 feet free of intervening combustibles or fire hazards. The purpose of the rule.is to assure that sufficient undamaged equipment is available to support safe shutdown assuming a fire within the area of concern. The twenty feet of separation free of intervening combustibles between redundant shutdown systems provides adequate time for the fire brigade to respond to a fire and protect at least one train.
The 33 feet separating these redundant valves contains intervening combustibles in the form of cable insulation. Cable insulation initially
burns slowly with much smoke and low heat release. Existino fire detection systems would actuate during the formative stages of a fire allowing the fire brigade ample time to respond to the fire before both trains were lo t.
- Thus, the underlying purpose of the rule is achieved.
5.
III.G.2; exemption requested to allow manual operation in lieu of providing fire protection for certain cables associated with emergency feedwater system valves in area IB-FZ-8: The technical requirements of Appendix P are not met in this area because circuits for redundant emergency feedwater system valves are not protected per the options identified in Section III.G. As summarized in our evaluation in Exemption 2, on the basis that a fire which occurs in IB-FZ-8 will not spread such as to effect the manual operators for valves EF-V30A thru D, and on the basis that plant procedures and personnel are adequate to perform the necessary tasks within the time frame stipulated by the licensee, the absence of physical protection for these circuits.is not significant.
The staff concludes that the licensee's alternate fire protection configuration provides an equivalent level of safety to that achieved by compliance with Section III.G. of Appendix R.
The special circumstances of 10 CFR 50.12 apply in that application of the regulation in the particular circumstances is not necessary to achieve the underlying purpose of the rule. The underlying purpose of the rule is to accomplish safe shutdown in the event of a single fire and maintain the plant in a safe condition. The rule requires fire protection for circuits and components associated with shutdown-related valves and pumps. However, j
certain valves can withstand the effect of a fire and still be manually i
. operated. Sufficient time exists to allow this manual operation and maintain the plant in a safe shutdown condition. Thus, the underlying purpose of the rule is satisfied allowing manual operation of these components.
dditionally, the licensee argues that providing additional protection features, as required by the regulations, would not result in a significant increase in the level of protection provided and would result in undue hardship and costs significantly in excess of those incurred by others similarly situated. These costs consist of additional engineering, procurement of materials, fabrication, and installation costs.
6.
III.G.3; exemption requested from installing a fixed fire suppression systen in the control room: The staff was concerned that if a fire of significant magnitude occurred, it would damage redundant shutdown systems and prevent the plant from achieving and maintaining safe shutdown conditions. However, the area is equipped with a smoke detection system as described in the FHAP.
If a fire were to occur, it would be detected in its formative stages by this system or by the plant operators who are always present. The fire would be able to be suppressed before significant damage occurred by the use of portable fire fighting equipment.
If a significant fire resulted which would force control room evacuation, the licensee states that the plant can be safely shut down using the alternate shutdown capability which is independent of this fire area.
Pending eventual fire extinguishment, the continuous fire-rated boundary construction of the control room would be able to confine the effects of the fire to the area of origin. Therefore, a fixed fire suppression system is not necessary to assure safe plant operation.
Based on the above evaluation, the staff concludes that the licensee's alternate fire protection configuration for the control room provides an equivalent level of safety to that achieved by compliance with Sec[ ion III.G.3.
The special circumstances of 10 CFR 50.12 apply in that application of the regulation in the particular circumstances is not necessary to achieve the underlying purpose of the rule. The rule requires the installation of a fixed fire suppression system in an area which has been provided with an alternate shutdown capability. The underlying purpose of the rule is to accomplish safe shutdown in the event of a single fire and maintain the plant in a safe condition. This is accomplished by assuring that sufficient undamaged eouipment is available to support safe shutdown assuming a fire within the area of concern. The control room is continuously manned and has an installed smoke detection system. Thus, fires would be detected and extinguished in their formative stage. But in any event, the licensee has installed alternate shutdown capability which is independent of the control room. Thus, the underlying purpose of the rule is satisfied 7.
III.J; exemption requested from installing eight-hour battery powered emergency lighting in certain locations of the reactor building and control room: The staff's concern in the reactor building containment was that a reliable means of illumination be provided, that the path of travel be unobstructed and easily traversed, that the valves requiring manipulation be accessible and that portable lighting would be adequate for the task.
During a visit to the plant on November 13, 1986, the staff walked down the route of travel to the valves and observed the valve locations in relation to the floor and possible obstructions.
It is the staff's judgment
that because 1) the route of travel is open and unobstructed and does not require travel via ladders, 2) the valves are within reach when stapding on the floor, and 3) two operators will be performing the tasks tocetf br, each carrying a portable light, the use of portable lighting is an acceptable alternative in this instance.
The staff's concern in the control room was that a fire outside the area, concurrent with a loss of offsite power would result in the loss of all emergency lighting in the room. However, because the licensee will protect cables and components of one of the three emergency pnwer sources to the control room lighting in accordance with Section III.G.2, the staff has reasonable assurance that adequate emergency lighting will be available in the control room for a fire in any other area / zone.
Based on the licensee's commitments and plant conditions as described above, the staff concludes that the proposed alternate lighting will provide an equivalent level of illumination to that achieved by the installation of individual, fixed, eight-hour lighting units.
1 The special circumstances of 10 CFR 50.12 apply in that application of the regulation in the particular circumstances is not necessary to achieve the underlying purpcse of the rule. The regulations require individual eight-hour battery powered lighting units in areas required for safe shutdown and in access routes to such routes. The rule was designed to provide adequate, dependable lighting for operators under emergency conditions.
For the control room, the protected lighting will be supplied power from the station batteries or the diesel generators. Both of these power supplies are dependable and 2
would supply power for more than eight hours. Thus, the underlying purpose of the rule is achieved.
For the containment building, portable light,ing vice fixed lighting will satisfy the underlying purpose of the rule becbse (1) a very minimum number of valves are involved, (2) there is easy access to and from the valves and the valve operators, and (3) a minimum of two operators each with a portable light would be sent to operate the valves. Additionally, the licensee argues that compliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted. Specifically, providing additional permanently mounted emergency lighting units would not result in a significant increase in the level of plant safety and would result in undue costs for engineering, procurement of materials, fabrication, and installation.
For further details with respect to this action, see the licensee's letters requestino the exemptions and the NRC's evaluation dated December 30, 1986, of the licensee's fire protection program, which are available for public inspection at the Commission's Public Document Poom, 1717 H Street, N.W., Washington, D.C., and at the Government Publications Section, State Library of Pennsylvania, Education Building, Commonwealth and Walnut Streets, Harrisburg, Pennsylvania 17126.
i IV.
Accordingly, the Commission has determined that, pursuant to 10 CFR 50.12, this exemption is authorized by law, will not present an undue risk to the i
public health and safety, and is consistent with the common defense and security. The Commission further determines that special circumstances, as
i
- PC -
provided in 10 CFR 50.12(a)(2)(ii), are present justifyino the exemptior, namely that application of the regulation in the particular circums.tances is not necessary to achieve the underlying purpose of the rule. Specifics are discussed in each exemption request but in aeneral the underlying purpose of the rule is to accomplish safe shutdown in the event of a single fire and maintain the plant in a safe condition.
This is accomplished by assuring that sufficient undamaged equipment is available to support safe shutdown assuming a fire within the area of concern.
In the areas for which an exemption is being requested, passive as well as active fire protection features assure that any single fire will not result in the loss of safe shutdown capability.
These features include separation distance, fire barriers, sealed penetrations, water spray to preclude propagation, and manual actions. The fire protection features, in conjunction with low combustible loadings, provide a high degree of assurance that a single fire will not result in loss of safe shutdown capability.
In addition, the special circumstances of 10 CFR 50.12(a)(2)(iii) apply on that compliance would result in costs that are significantly in excess of those contemplated when the regulation was adopted. Providing additional protection features, as would be required to meet the regulations, would not result in a significant increase in the level of protection provided and would result in undue costs for additional l
engineering, procurement of materials, fabrication, and installation.
Accordingly, the Commission hereby grants the exemptions listed in Section III above from the requirements of 10 CFR 50, Appendix R.
d
- Pursuant to 10 CFR 51.32, the Commission has determined that the granting of this Exemption will have no significant impact on the environment (51 FR 45406).
This Exemption is effective upon issuance.
FOR THE NUCLEAR REGULATORY COMMISSION
/
t Frank Schroe r, Acting fre or Division of PWR Licensing-B Dated at Bethesda, Maryland this 30th day of December,1986.
l i
l 5
i l
i
.