ML20236H239

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Provides Info to Support Finding That Special Circumstances Exist,Per Rev to 10CFR50.12,concerning 840727 Request for Exemption from Requirements of 10CFR50,App R.Implementation of Listed Mods Would Be Extensive Undertaking
ML20236H239
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 10/30/1987
From: Leblond P
COMMONWEALTH EDISON CO.
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
3773K, TAC-55582, TAC-55583, NUDOCS 8711030550
Download: ML20236H239 (3)


Text

i I

/3 Commcnw:alth Edison j

/

C / Ons First National Plaza, Chicago, Illinois-

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Address Rtply to: Post Office Box 767

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/ Chicago, Illinois 60690 0767

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i october 30, 1987 U.S. Nuclear Regulatory Commission Attn: Document Control Desk y

Washington, DC 20555

Subject:

Zion Nuclear Power Station Units 1 and 2 10 CFR 50, Appendix R Exemptions j

NRC Docket Nos. 50-295 and 50-304 l

TAC Noc. 55582/3 l

References (a): July 27, 1984 letter from R.N. Cascarano j

to H.R. Denton (b): August 31, 1984 letter from R.N. Cascarano to H.R. Denton 1

(c): January 24, 1985 letter from R.N. Cascarano j

to H.R. Denton 1

(d):

February 18, 1986 letter from P.C. LeBlond l

to H.R. Denton (e):

February 9, 1987 letter from P.C. LeBlond j

to H.R. Denton

]

(f): September 10, 1987 letter from P.C. LeBlond to U.S. NRC Gentlemen:

Commonwealth Edison Company has previously requested a number of exemptions from the requirements of 10 CFR 50, Appendix R'.

These requests were originally sabmitted in reference (a) and augmented in references (b) through (f). The initial request was prepared prior to the revision to 10 CFR 50.12 that added the requirement for the NRC Staff to make a positive finding regarding the existence of "special circumstances". This submittal is providing information to support that finding.

References (a) through (f) have transmitted a current total of six active exemption requests to 10 CFR 50, Appendix R.

These six exemptions are briefly described below.

1.

Main Contro? Room, Fire Zone 2.0-0.

Lack of a fixed fire suppression system throughout the main control room.

2.

Auxiliary Electric Equipment Rooms, Fire Areas 5.6-1 and 5.6-2.

Lack of a fixed fire suppression system throughout each AEER.

00 8711030550 871030 PLR ADOCK 05000295 F

PDR

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I US MRC October 30, 1987 3.

Auxiliary Building, Component Cooling Water Pump Area, Elevation 560 Feet.

Lack of fixed automatic suppression and detection systems and 20 feet of separation free of intervening combustibles between redundant safe shutdown equipment for the 560-foot elevation of the auxiliary building j

fire area.

l 4.

Auxiliary Building, Elevations 592, 617, and 642 Feet.

Lack of automatic fire suppression and detection systems and 20 feet of separation free of intervening combustibles between redundant safe shutdown components.

5.

Main Steam Pipe Tunnels (Fire Zones 18.5-1 and 18.5-2).

Lack of full area detection and automatic fire suppression.

6.

Auxiliary Building, Auxiliary Feedwater Pump Area, Elevation 579 Feet.

Lack of automatic fire suppression end detection systems and 20 feet of l

separation between redundant safe shutdown components on the 579-foot elevation of the auxiliary building fire area.

10 CFR 50.12 a.2.ii states:

(2) The Commission will not consider granting an exemption unless special circumstances are present. Special circumstances are present whenever - (ii) Application of the regulation in l

the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule.

References (a), (d), (e), and (f) provided technical justification for the exemptions. These justifications demonstrated that the six exemptions, if approved by the NRC Staff, would provide an equivalent level of fire protection to that described by Appendix R.

Thus, compliance with a strict reading of 10 CFR 50, Appendix R is not necessary to achieve the underlying purpose of the rule. Since the six exemption requests described above and in references (a) through (f) provide an equivalent level of fire protection for Zion Station, "spr.cial circumstances" as described in 10 CFR 50.12.a.2.ii exist.

I

US MRC October 30, 1987 i

In addition, should one exemption requests be denied, numerous I

modifications would be necessary to achieve full compliance with a strict reading of 10 CPR 50, Append!x R.

A brief description of the modifications that might be required is provided below.

1.

Install fixed fire suppression systems for the Main Control Room and Auxiliary Electric Equipment Rooms, i

2.

Install an automatic fire suppression and detection system in the Main i

Steam pipe Tunnels and in the Auxiliary Building, elevations 560', 579',

j 592' 617', and 642'.

3.

Install multiple rated fire barriers in the Auxiliary Building elevations 560', 579', 592', 617', and 642'.

i The implementation of the modifications described above would be an extensive undertaking.

These modifications would require an extremely large l

manpower commitment.

In addition, the financial requirements would be substantial. While no formal engineering cost estimate has been prepared, l

modification programs similar to the above typically involve in, excess of several million dollars. As discussed above, this increased burden is not i

necessary to achieve the underlying purpose of 10 CFR 50, Appendix R.

If any questions arise regarding this matter, please direct them to j

this office.

l Very truly yours, d

}r P. C. LeBlond Nuclear Licensing Administrator i

cc: Resident Inspector - Zion J. A. Norris - NRR l

3773K s

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