ML20212M881

Exemption from Schedular Requirements of 10CFR50.48 for Mod to Switchgear Room & Related Plant Areas,To Assure Adequate Level of Fire Protection,Subj to Licensee Submittal of Implementation Plan by 860930 & Subsequent Bimonthly Repts

ML20212M881
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	08/25/1986
From:	Harold Denton Office of Nuclear Reactor Regulation
To:	CONNECTICUT YANKEE ATOMIC POWER CO.
Shared Package
ML20212M877	List: ML20212M876 ML20212M879 ML20212M881 ML20212M885
References
GL-86-10, NUDOCS 8608270356
Download: ML20212M881 (7)

Text

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UNITED STATES OF AMERICA .

NUCLEAR REGULATORY COMMISSION In the matter of Docket No. 50-213 CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM NECK PLANT f

EXEMPTION I.

The Connecticut Yankee Atomic Power Company (CYAPC0, the Licensee) is the hol. der of Operating License No. DPR-61 which authorizes operation of the Haddam Neck Plant. The license provides, among other things, that the Haddam Neck Plant is subject to all rules, regulations, and Orders of the Commission now or hereafter in effect.

The plant i.s a single-unit pressurized water reactor at the licensee's site located in Middlesex County, Connecticut.

II.

On November 19, 1980, the Comission published a revised Section 50.48 and a new Appendix R to 10 CFR Part 50 regarding fire protection features of l nuclear power plants. The revised Section 50.48 and Appendix R became j effective on February 17, 1981.Section III of Appendix R contains 15 sub-sections, lettered A through 0, each of which specified requirements for a particular aspect of the fire protection features at a nuclear power plant.

The licensee has submitted a request for exemption frcm the schedular requirementsof10CFR50.48(c)inaccordancewith'theprovisionsof ,

10 CFR 50.12(a)(2)(v) for a temporary exemption. Such a temporary exemption requires a demonstration by the licensee that it has made good faith efforts to comply with the applicable regulatory requirements. Further, Generic Letter 86-10 contains four criteria used by the staff to evaluate whether a licensee has demonstrated a good faith effort to meet the requirements under 10 CFR 50.48.

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These criteria are:

1) The utility has, since the promulgation of Appendix R in 1980, j proceeded expeditiously to meet the Connission's requirements.

{ 2) The delay was caused by circumstances beyond the utility's

. control.

! 3) The proposed schedule for completion represents a best effort l under the circumstances'.

4) Adequate interim compensatory measures will be taken until compliance is achieved. -

, III.

j Background l By a letter dated July 16, 1982 CYAPC0 requested an exemption from. .

f Section III.G.2.of Appendix R. 10 CFR Part 50 which proposed to relocate

} redundant shutdown systems within the switchgear room in lieu of providing alternate shutdown capability. CYAPC0 indicated at that time that the cost

of an independent, alternate shutdown capability would be prohibitive. In ,

! a draft safety evaluation ' dated November 3,1982, the staff accepted CYAPC0 proposal for this area. The staff's final safety evaluation was issued by l letter dated November 14, 1984, in conjunction with the granting of eight exemptions from the requirements of Section III.G of Appendix R and approval of other plan +. modifications for the Haddam Neck plant to achieve compliance j with Appendix R. Tocomplywiththeschedularrequirementsof10CFR50.48(c),

i these modifications were to be completed before startup frorn the 1986 outage, which subsequently commenced on January 4,1986.

By letter dated March 7,1986, CYAPC0 requested a temporary exemption l from the schedular requirements of 10 CFR 50.48(c), which would defer implementation of the modifications to meet the requirements of Section

• 1 III.G of Appendix R for fire areas A-1, R-1, R-3, S-2, S-3, and T-1, in order to pursue a new approach for the switchgear room. Rather than relocating redundant electrical divisions for safe shutdown equipment witnin i

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the existing switchgear room and related plant areas, the licensee now proposes to construct a new building housing a switchgear room that would accommodate one shutdown division. The proposal associated with this exemption request is intended to resolve a number of other issues (tornado missiles, standby DC power, internal missiles and high energy pipe break effects), and, as such, represents a significant improvement in fire protection capability and overall plant safety as compared to the modifications referred to in the staff's November 1984 safety evaluation. The planning, construction and testing associated with this proposal would, subject to staff review, require schedular relief until start-up following the currently planned 1989 outage. This schedular extension would also apply to the specified fire areas which contain redundant shutdown-related cables that are impexted by the newly proposed switchgear room modifications.

l l Evaluation Criteria As stated in Section II above, the Commission provided criteria to be considered when granting schedular exemptions under 10 CFR 50.12(a)(2)(v).

The following is a discussion of how these four criteria have been satisfied.

1) The utility has, since the promulgation of Appendix R in 1980, proceeded expeditiously to meet the Commission's requirements.

Since the issuance of 10 CFR 50 Appendix R CYAPC0 has undertaken a number of fire protection reviews and evaluations, and has implemented many fire protection modifications. On March 19, 1981, CYAPC0 provided the NRC with the results of an initial comparison to Appendix R. The initial comparison to Appendix R and sut. sequent submittals resulted in numerous meetings with the Staff during the period of 1981 through 1984. Numerous Staff clarifications during this period r(quired additional submittals which culminated in a ,

favorable resolution of a related control room exemption request, ss described in the staff's November 1984 safety evaluation.

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To date, CYAPC0 has performed fire protection modifications costing in excess of $3 million and the proposed switchgear room modifications will cost approximately an additional $10 million to complete. With the exception of 8 pending exemption requests, all other fire protection modifications have been completed.

Based on the above, the Commission concludes that the completed modifications reflect a reasonable effort to expeditiously comply with the requirements of 10 CFR 50 Appendix R.

2) The delay was caused by circumstances beyond the utility's control.

In a somewhat unique approach to the resolution of fire protection requirements, CYAPC0 prepared a risk-related document for specific plant fire areas. In March of 1982, the switchgear room, as preser.tly configured, was determined, based on the consultants' study, to be a negligible contributor to risk via internal fire events. Thus, rajor modifications to this fire area (S-2) were not proposed by the licensee. CYAPC0 later determined that the PRA consultant had made a major error in the switchgear assumptions which, when corrected, significantly impacted the calculated risk. ,

The resolution of the fire protection provisions for the control room, as described in the staff's November 1984 safety evaluation, included the need for a new remote instrumentation panel in the south end cf the switch-gear room. Related plant modifications further complicated tie modification design for the switchgear room and exacerbated the congestion in that area.

In June 1983, the staff isiued the Integrated Plant Safety Assessment Report for the Haddam Neck plant (NUREG-0826) which identified plant modifications and additional engineering studies resulting from the Commission's Systematic Evaluation Program (SEP). The licensee recognized that the contemplated modifications to the switchgear room could affect the i resolution of several SEP issues. The licensee subsequently determined that resolution of all of the issues related to the switchgear room would require that the modifications would have to be moved outside the switchgear room.

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CYAPC0 eventually contracted the services of a consultant to develop a feasibility study of design alternatives to resolve all of the issues for the switchgear room. This study resulted in the proposal presented in the licensee's March 7, 1986 schedular exemption request. The current proposal

, represents a significant. improvement in both fire protection capability and overall plant safety as compared to the earlier modification design concept.

While it is not entirely clear to the staff why the proposed conceptual design for the switchgear room could not have been developed earlier, some of the delay resulted from circumstances beyond the licensee's control. The staff ,

agrees that the licensee was justified in awaiting resolution of all switchgear room issues before consnitting substantial resources to plant modifications which would also resolve the fire protection problem. While this judgment is a close one, the staff finds that this criterion is satisfied.

3) The proposed schedule for completion represents a best effort s

under the circumstante_s.

The licensee's March 7, 1986 letter presents a schedule for the proposed modifications including esi.imates for the lead time required for detailed design engineering, purchasing of all required equipment, and related construction activities. In view cf the magnitude of the proposed modifications and the lead time required to procure the necessary equipment, the staff agrees with the licensee's assessment that it would not be possible to perform all required modifications by the end of the next refueling outage. The staff concluded that, given that certain modifications can only be perfonned during refueling outages, the licensee's scheduled completion within two refueling outages represents a best effort possible under the circumstances.

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4) Adequate interim compensatory measures will be taken until l compliance is achieved. '

The existing fire protection for the switchgear room and related areas consists of a smoke detection system, an automatic Halon fire extinguishing system or an automatic carbon dioxide suppression system, manual hose stations, and portable fire extinquishers. In addition, the licensee has proposed compensatory measures, in the form of a continuous fire patrol, (i.e., twenty-minute rounds) for the affected areas. The staff concludes that the continuous 1

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fire patrol, in conjunction with the fire detection and suppression systems in the switchgear room and related plant areas provide reasonable assurance that any fire would be detected and extinquished before redundant divisions are affected by a fire in any one of the specified fire areas of sufficient size ,

to cause a loss of safe shutdown capability. On this basis, the staff further concludes that plant operation, in the interim, will not present an undue risk to the public health and safety.

IV.

Accordingly, the Commission has detennined that, pursuant to 10 CFR 50.12(a)(2)(v), the exemption would provide only temporary relief and the licensee has made a reasonable effort to ccmply with the schedular requirements of 10 CFR 50.48, in conjunction with the resolution of other important safety issues. The requested exemption is authorized by law and will no't endanger life or property or the comon defense and security.

Therefore, the Comission hereby grants a temporary exemption from the requirements of 50.48(c) and Section III.G of Appendix R to 10 CFR Part 50, with respect to' separation of electrical divisions in fire areas A-1A, A-1B, A-1C, A-10, R-1, R-3, S-2, S-3 and T-1 at the Haddam Neck plant until the end of the Cycle 15 refueling outage.

The granting of this exemption is subject to the licensee's submittal of major implementation milestones by September 30, 1986, and subsequent bimonthly progress reports. This exemption is also contingent on implementation of the comitments in the licensee's letter dated July 3,1986, which resulted from the fire protection inspection audit on June 16-20, 1986. These modifications will substantially improve the existing fire protection capability at the Haddam Neck plant in the interim. Failure to meet any milestone or implement any comitments will be considered a violation of the terms of the exemption and may result in the voiding of the exemption and subsequent. enforcement /

coniplianc.e action.

The Director, Office of Nuclear Reactor Regulation may grant changes to interim dates of the completion schedule if the licensee's request is timely I and shows good cause for the proposed change. However, the completion date for the fire protection modifications will remain the startup from the l cycle 15 outage. l

Pursuant to 10 CFR 51.32, the Comission has determined that the granting of this exemption will have no significant impact on the environment (51 FR 17696, May 14, 1986).

A copy of the Safety Evaluation dated August 25, 1986, related to this action .is e.vailable for public inspection at the Comission's Public Document Room, 1717 H Street, N.W., Washington, D.C. and at the local public document room located at the Russell Library,123 Broad Street, Middletown, Connecticut 06457. A copy may be obtained upon written request addressed to the U.S.

Nuclear Regulatory Comission, Washington, D.C. 20555. Attention: Director Divistoa of PWR Licensing-8.

T'iis Exemption is effective upon issuance.

Dated at Bethesda, Maryland this 25th day of August,1986 FOR THE NUCLEAR REGULATORY COMMISSION A

Harold R. Denton, Director Office of Nuclear Reactor Regulation 4

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