ML20214V971
| ML20214V971 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 12/03/1986 |
| From: | Cutter A CAROLINA POWER & LIGHT CO. |
| To: | Muller D Office of Nuclear Reactor Regulation |
| References | |
| NLS-86-095, NLS-86-95, NUDOCS 8612100029 | |
| Download: ML20214V971 (6) | |
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Carolina Powsr & Light Cornpany SERIAL: NLS-86-095 DEC 0 31986 Director of Nuclear Reactor Regulation Attention:
Mr. Dan Muller, Director BWR Project Directorate #2 Division of BWR Licensing United States Nuclear Regulatory Commission Washington,' DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 & 50-324/ LICENSE NOS. DPR-71 & DPR-62 EXEMPTION REQUEST SECTION III.3 OF APPENDIX R
Dear Mr. Muller:
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Carolina Power & Light Company (CP&L), pursuant to the provisions of 10 CFR 50.12, hereby applies for a technical exemption from the requirements of 10 CFR 50, Appendix R,Section III.3. We request an exemption from having to provide 8-hour battery powered emergency lighting units for the Brunswick Steam Electric Plant Control Room because the existing emergency lighting system provides equivalent lighting.
SPECIFICS OF THE EXEMPTION We request an exemption from the emergency lighting requirements of 10 CFR 50, Appendix R,Section III.3 for Fire Zone CB-23 which is located in Fire Area CB-23E.
This exemption is limited only to providing separate emergency lighting units for the operation of safe shutdown equipment from the Control Room area. Eight-hour battery units are provided for access and egress from the area if it becomes necessary to vacate the Control Room to execute remote shutdown. Attachment I to this letter provides the i
j technical justification for the exemption request and supplementary information to aid in i
your review.
PROVISIONS OF 10 CFR 50.12 Authorized by Law and No Undue Risk Considerations We have determined that this request is authorized by law, will not present an undue risk to the public health and safety, is consistent with the common defense and security, and that granting this exemption is not in violation of other applicable laws, such as the Atomic Energy Act or the National Environmental Policy Act.
We believe that this exemption will not present an undue risk to the public health and i
safety because of the existing equivalent measures, as described in Attachment 1 (i.e.,
the existing emergency lighting system for the Control Room area), which provides lighting equivalent to that specified in Section llI.3 of Appendix R.
8612100029 861203 PDR ADOCK 05000324 Y9 411 Fayetteville Street
- P. o. Box 1551
- Raleigh. N C. 27602 h 4
.+ -
i Mr. Dan Mullrr
' Pega 2 / NLS-86-095 Special Circumstances There is a special circumstance which warrants granting this exemption as provided by the Commission in Section 50.12(aX2Xii).
Application of 10 CFR 50, Appendix R, Section Ill.3 is not necessary to achieve the underlying purpose of the rule. The specific objective of the regulation is the assurance of lighting to aid the access to equipment and components that must be manually operated by plant personnel to effect safe plant shutdown during plant emergencies (45 FR 76602, dated November 19,1980, Fire Protection Program for Operating Nuclear Power Plants, Statements of Consideration). The Brunswick design fulfills this underlying purpose through the existing emergency lighting system as described in. The existing emergency lighting system for the Control Room area provides lighting equivalent to that specified in Section III.3 of Appendix R, and maintains the Control Room illuminated under fire conditions which may occur exterior to the control building and which may require shutdown activities from the Control Room.
Pursuant to 10 CFR 170.12, a check for $150 in payment of the exemption application fee is enclosed.
Should you have any questions regarding this request, please contact Mr. Patrick Carier at (919) 836-8165.
Yours very trul y
//
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A. B. Cutter - Vice Pre dent Nuc! car Engineering & Licensing ABC/PPC/ccj (3583CGL)
Enclosures cc:
Mr. W. H. Ruland (NRC-BNP)
Dr. 3. Nelson Grace (NR C-Ril)
Mr. E. Sylvester (NRC' i
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o ATTACHMENT 1 10CFR50, Appendix R,Section III.J Exemption Request Technical Justification (3343PPC/pgp )
o EMERGENCY LIGHTING EXEMPTION REQUEST Summary An exemption from having to provide eight-hour battery powered emergency lighting units is requested for the Brunswick Control Room (Fire Zone CB-23).
Basis for Exemption The Control Room area is common to both units and area lighting is provided equally by each unit. Every other light fixture in the area is fed from the opposite unit. The normal AC lighting power sources for the Control Room area are physically separated by the length of the Control Building since the cables enter the building at opposite ends.
This arrangement will assure that adequate Control Room lighting will be provided for any fire where safe shutdown is accomplished from the Control Room.
The Control Room area is the only area where both sources of power come in close proximity. A Control Room fire significant enough to damage both lighting power sources would result in an evacuation of the area. For this condition, egress lighting (eight-hour battery units) from the area has been installed.
For a fire in any area outside the Control Room, adequate Control Room lighting will be provided by either the diesel generators or the station batteries. This combination will assure that lighting is provided for a duration which would meet and, in fact, exceed the eight-hour requirement in paragraph III.3 of Appendix R.
The underground (yard) routing of Train A and Train B as well as their routing inside the Reactor Building is discussed in the Alternative Shutdown Capability Assessment Report submitted in April 1984. The report shows that a single credible fire either in the building or in the yard will not result in a loss of both trains from both units. Therefore, a single credible fire exterior to the Control Building will not cause a loss of AC lighting.
Description Fire Zone CB-23 is located on the 49 ft. elevation of the Control Building. The zone is occupied primarily by the Units 1 and 2 Control Room area and associated ancillary control panels and cabinets.
Normal lighting in the Control Room area is from four (4) 480 volt unit substations which
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are in turn powered from four (4) 4160 volt emergency system switchgear. Each 480 volt and 4160 volt switchgear is located in a separate room in the Diesel Generator Building.
Each switchgear room is separated from the remainder of the building by three-hour l
rated fire barriers. Each 4160 volt emergency bus is provided with a dedicated emergency diesel generator which is designed to automatically start and ties itself to the bus within 10 seconds on loss of off-site power.
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The routing of the lighting circuits from the Diesel Generator Building to the Control Building is the same as for divisionalized Class IE circuits which are powered from the 480 volt boards (see Figure 1). The normal lighting source for Unit 1 is Substation E6 which is Division II or Train B. The lighting cables are routed in Division II underground l
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. o bus ducts from the Diesel Generator Building to the Reactor Building where they enter the building near the southeast corner at the (-) 17 f t. elevation. From there the cables are routed in Division !! (Train B) raceways to the Control Building. An alternate source is unit Substation E5 which is Division I or Train A. These cables are routed through Division I underground bus ducts from the Diesel Generator Building to the Reactor Building where they enter the building near the northeast corner at the (-) 17 ft.
elevation. From there they are routed in Division I(Train A) raceways to the Control Building. Train A and Train B enter the Control Building at the north end.
Inside the Control Building, the normal and alternate sources of power feed a lighting distribution panel through a transfer switch which automatically transfers to the alternate source upon loss of the normal power. In addition to these AC sources, the distribution panel can also be powered by the station batteries through an inverter.
250 volt DC Switchboards IB (located in Battery Room IB) and 2B (located in Battery Room 2B) power the distribution panel. Switchboard 2B is considered the normal DC power source and IB is the alternate.
The arrangement of the circuits and components discussed above are similarly arranged for Unit 2 with Substation E8 (Division II) being the normal AC source and E7 (Division 1) being the alternate. The circuits enter the Control Building at the south end.
Switchboard IB is the normal DC source and 2B is the alternate.
Conclusion Based on the above, CP&L believes that the existing emergency lighting system for the Control Room area will: l) provide lighting equivalent to that specified in Section 111.3 of Appendix R, and 2) maintain the Control Room illuminated under any fire condition which may occur exterior to the Control Building which requires shutdown activities from the Control Room. Therefore, not installing eight-hour battery powered emergency lighting units will not degrade BSEP's safe shutdown capability,
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