ML20213G450
| ML20213G450 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 11/06/1986 |
| From: | Novak T Office of Nuclear Reactor Regulation |
| To: | VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| Shared Package | |
| ML20213G452 | List: |
| References | |
| NUDOCS 8611180127 | |
| Download: ML20213G450 (8) | |
Text
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.
7590-01 UNITED STATES NUCLEAR REGULATORY COMMISSION In the matter of i
Docket Nos. 50-338 and
-)
50-339 VIRGINIA ELECTRIC
)
AND POWER COMPANY l
i North Anna Power Station
)
Units 1 and 2
)
EXEMPTION I
The Virginia Electric and Power Company (VEPCO, the Licensee) is the holder of Operating License No. NPF-4 which authorizes operation of North Anna Power Station Unit I and Operating License No. NPF-7 which authorizes operation of Unit 2.
These operating licenses provide, among other things, that the North Anna Power Station is subject to all rules, regulations, and Orders of the Commission now or hereafter in effect.
The station comprises two pressurized water reactors at the Licensee's site located in Louisa County, Virginia.
l II.
On November 19, 1980, the Commission published a revised Section 50.48 and a new Appendix R to 10 CFR 50 regarding fire protection features of nuclear power plants. The revised Section 50.48 and Appendix R became effective on February 17, 1981.Section III of Appendix R contains 15 subsections, lettered A through 0, each of which specified requirements for a particular aspect of f
the fire protection features at a nuclear power plant. Two of these f
subsections, III.G and III.J are the subject of the Licensee's exemption requests.
8611180127 861106 PDR ADOCK 05000338 F
2-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 associeted nonsafety circuits of redundant trains by a fire barrier having a 3-hour rating.
Structural steel forming a part of or supporting such fire barriers shall be protected to provide fire resistance equivalent to that required of the barrier.
b.
Separation of cables and equipment and associated nonsafety circuits s
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 area.
c.
Enclosure of cable and equipment and associated nonsafety circuits of one redurdant 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 and a fixed fire suppressien system shall also be installed in the area, room, or zone under consideration.
Subsection III.J of Appendix R requires that emergency lighting units with I
at least an 8-hour battery-powered supply be provided in all areas needed for operation of safe :hutdown equipment; and in access and egress routes thereto.
1 i
4 m,. _ _ _ _ _ _ _.... -. _ _ _ _ -,,,. -,, -. _ _ _ - -
_l
. III.
By letters dated May 1,1984, the Licensee requested exemptions from Sections III.G and III.J of Appendix R.,By letters dated October.31, 1984, August 21, 1985, ar;d March 21, 1986, the Licensee ~ transmitted revisions to their Appendix R evaluation. These exemption requests are the subject of this report.
The following list of exemption requests, therefore, reflects the latest status:
1.
Auxiliary, Fuel, and Decontamination Buildings (Fire Area 11).
An exemption was requested from the specific requirement of Section III.G.3 to the extent that full area fire detection and fixed suppression systems are not installed throughout the area.
2.
Containment Incore Instrument Tunnel (Fire Arecs 1-1 and 1-2).
An exemption was requested from the specific requirement of Section III.G.2.d to the extent that intervening combustibles exist between redundant cables and equipment.
3.
Ouench Spray Pump House (Fire Areas 15-1 and 15-2).
An exemption was requested from the specific reouirenent of Section III.G.3 to the extent that automatic fire suppression systems are not installed throughout the fire areas.
4.
Main Steam Valve House (Fire Areas 17-1 and 17-2).
An exemption was requested from the specific requirement of Section III.G.3 to the extent that automatic fire suppression systems are not installed throughout each fire area.
5.
Auxiliary Feedwater Pump House (Fire Areas 14B-1 and 148-2).
An exemption was reauested from the specific requirement of Section III.G.3 to the extent that automatic fire suppression systems are not installed throughout the fire areas.
. 6.
Charging Pump Cubicles (Elevation 244 Feet, 6 Inches).
An exemption was requested from the specific requirement of Section III.G.2.a to the extent that nonrated removable concrete walls do not
~
providea3-hourfireresiskancerating.
7.
Sepa*ation of Instrumentation Inside the Containment (Fire Areas 1-1 and 1-2).
An exemption was requested from the specific requirement of Sectior III.G.2.d to the extent that intervening combustibles exist between redundant cables and equipment separated by 20 feet or by radiant energy shields.
8.
Emergency Lighting in the Seal Water Filter Area, Main Control Room, and Exterior Access Routes.
An exemption was requested from the specific requirement of Section III.J to the extent that it requires 8-hour emergency lighting irt all areas needed for operation of safe shutdown equipment; and in access and egress routes thereto.
9.
Chiller Rooms (Elevation 254 Feet, O Inch of the Service Building).
An exemption was requested from the specific requirements of Section III.G.2.a to the extent that ventilation penetrations through fire barriers are not provided with fire dampers.
- 10. Auxiliary Building Ventilatier. Equipment Area, Fire Aree 11.
An exemption was requested from the specific recuirement of Section III.G.2.b to the extent that full area detection and suppression are not provided.
In sumary, the exemptions were requested from sepItrating cables and 0
associated nonsafety circuits of redundant trains by 3Ih'our rated fire barriers as required in Section III.G.2.a of Appendix R, and from providing automatic fire suppression and detection systems as part of the protection requirements of Sections III.G.2.b and III.G.3 of Appendix R.
Additionally, exemptions from the intervening combustible requirements of Section III.G.2.b and the emergency lighting requirements of Section III.J we e requested.
The Licensee has provided alternative and/or acceptable levels of fire
- protection for areas containing redundant safe shutdowkIsystems not separated Fire protection in areas containing.2 move than the negligible from each other.
combustible load and containing safe shutdown equipment or cables consists of fire detectors and/or automatic fire suppression systems, 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 by the fire brigade. The low combustible loading ensures tha,t redundant safe shutdown equipment located in the adjoining areas will not be: damaged beforp the fire brigade can extinguish the fire.
Based on the review of the Licensee's analyse $, the sta#f concludes that the level of fire protection provided is equivaledt to the technical reouirements of Sections III.G and III.J of Appendix R.
Additional details concerning the exemptions are provided in the safety evaluation dated November 6,198ti.
By letter dated September 30, 1986, the Licensee provided information relevanttothe"specialcircumstances"findingrekuiredbyrevised10CFR 50.12(a) (see 50 FR 50764). The Licensee stated that existing and proposed fire protection features at North Anna Power Station Units 1 & 2 accomplished the underlying purpose of the rule.
Implementing additional modif,1 cations to
O 4
. provide additional suppression and 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 the licensee's resources. The Licensee stated that it would be necessary tc design and install modifications to provide additional fire detection and fire suppression systems, fire barriers, fire doors and dampers, emergency lightina, and instrumentation. Additional dedicated personnel may be required.
Engineering and construction support would be necessary to reroute substantial amounts of existing cable and conduit and install fire-rated wrap and conduit seals.
Increased surveillance, test and maintenance effort would be necessary to support the new or augmented systems. Overall, these changes would require a significant expenditure of engineering, construction, and operations resources, as well as associated capital costs.
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 50.
See 10 CFP 50.12(a)(2)(ii).
IV.
Accordingly, the Commission has detennined that, pursuant to 10 CFR 50.12(a), (1) these exemptions as described in Section IIT are authorized by law and will not present an undue risk to the public health and safety and are 4
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 i
Appendix R to 10 CFR 50. Therefore, the Commission hereby grants the following
7-exemptions from the requirements of Sections III.G and III.J of Appendix R to 10 CFR 50:
1.
Auxiliary, Fuel, and Decontamination Buildings (Fire Area 11) to the extent that automatic fire suppression and detection systems are not installed throughout the fire area pursuant to Section III.G.3.
2.
Contairment Incore Instrument Tunnel (Fire Areas 1-1 and 1-2) to the extent that safe shutdown cables and equipment are not separated by 20 feet of separation with no intervening combustibles pursuant to the requirements of Section III.G.2.d.
3.
Quench Spray Pump House (Fire Areas 15-1 and 15-2) to the extent that automatic fire suppression systems are not installed throughout the areas pursuant to Section III.G.3.
4.
Main Steam Valve House (Fire Area 17-1 and 17-2) to the extent that automatic fire suppression systems are not installed throughout the fire areas pursuant to Section III.G.3.
5.
Auxiliary Feedwater Pump House (Fire Areas 148-1 and 14B-2) to the extent that automatic fire suppression systems are not installed throughout the fire areas pursuant to Section III.G.3.
6.
Charging Pump Cubicles (Elevation 244 Feet, 6 Inches) to the extent that redundant safe shutdown cables and equipment are not seperated by a 3-hour rated fire barrier pursuant to Section III.G.2.a.
7.
Separation of Instrumentation Inside the Containrent (Fire Areas 1-1 end I-2) to the extent that safe shutdown cables and equipment separated by 20 feet, or radiant energy shields are not free of intervening combustibles pursuant to Section III.G.2.d.
-_______._--_..-__,___,.___,-.____.-_.-_y,
. 8.
Emergency Lighting in the Seal Water Filter Area, Main Control Room, and Exterior Access Routes to the extent that 8-hour battery-powered emergency lighting is not provi,ded pursuant to.Section III.J.
9.
Chiller Rooms to the extent that redundant safe shutdown cables and equipment are not separated by a 3-hour rated fire barrier pursuant to Section III.G.2.a.
- 10. Auxiliary Building Ventilation Eouipment Area (Fire Area 11) to the extent that full area detection and suppression are not provided.
Pursuant to 10 CFR 51.32, the Commission has determined that the granting of these exemptions will have no significant impact on the environment (51 FR 35708).
A copy of the Safety Evaluation dated November 6,1986, related to this action is available for public inspection at the Commission's Public Document Room, 1717 H Street, N.W., Washington, D.C. and at the local public document rooms located at the Board of Supervisors Office, Louisa County Courthouse, Louisa, Virginia 23093 and the Aldeman Library, Manuscripts Department, University of Virginia, Charlottesville, Virginia 22901. A copy may be obtained upon written request addressed to the U.S. Nuclear Regulatory Commission, Washington, D.C.
20555, Attention: Director, Division of PWD Licensing-A.
These Exemptions are effective upon issuance.
Dated at Bethesda, Maryland this 6th day of November,1986.
FOR THE NUCLEAR REGULATORY COMMISSION b
M Thomas M. Novak, Acting Director Division of PWR Licensing-A Office of Nuclear Reactor Regulation
-- - -_--