ML20203D200

Suppls 850313,0531,0626,0719 & 1018 Requests for Exemption from App R Requirements.Implementing Addl Mods to Comply W/ App R for All Areas of Plant Would Represent Unwarranted Burden on Util Resources

ML20203D200
Person / Time
Site:	Farley
Issue date:	07/16/1986
From:	Mcdonald R ALABAMA POWER CO.
To:	Rubenstein L Office of Nuclear Reactor Regulation
References
TAC-60030, TAC-60031, NUDOCS 8607210171
Download: ML20203D200 (2)

Text

,. A M iling Address Atibama Power Company 600 North 18th Street Post Office Box 2641 Birmingham, Alabama 35291 Telephone 205 783409)

R. P. Mcdonald Senior Vice President Flintndge Building

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v r.m Docket Nos. 50-348 50-364 Director, Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C.

20555 Attention: Mr. L. S. Rubenstein Gentlemen:

Joseph M. Farley Nuclear Plant - Units 1 and 2 10CFR50, Appendix R Exemption Requests Alabama Power Company ( APCo) submitted exemption requests by letter dated October 18, 1985 to the requirements of 10CFR50, Appendix R, based upon an NRC audit. This submittal supplemented letters dated March 13, 1985, May 31, 1985, June 26, 1985 and July 19, 1985.

In these exemption requests, APCo provided justifications for exemptions to the NRC's interpretation of 10CFR50, Appendix R.

These justifications document that the existing and proposed fire protection features at Farley Nuclear Plant accomplish the underlying purpose of the rule.

Implementing additional modifications to provide additional suppression systems, detection systems and fire barriers to comply with Appendix R for all areas of the plant would require the expenditure of engineering and construction resources as well as the associated capital costs which would represent an unwarranted burden on APCo's resources. Costs that would be incurred are as follows:

- Engineering, procurement and installation of additional piping, sprinkler heads, and supporting structures.

Engineering, procurement and installation of additional fire barriers, supports, support protection and ongoing maintenance.

Significant rerouting of power cabling and associated conduits, ducts and supports.

Increased surveillance on new or extended fire suppression and fire detection systems.

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- Increased congestion in numerous plant locations complicating future plant modifications / operations.

0607210171 860716 PDR ADOCK 0D000348 PDR F

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1 Mr. L. S. Rubenstein July 16, 1986 U. S. Nuclear Regulatory Commission Page 2 These costs are significantly in excess of those required to meet the underlying purpose of the rule. Special circumstances exist since the application of 10CFR50, Appendix R in these particular circumstances are not necessary to serve the underlying purpose of the rule, and compliance would result in undue hardship and costs that are significantly in excess of those contemplated when the regulation was adopted. Consequently, the exemption requests from the provisions of 10CFR50, Appendix R, transmitted by the above referenced letters, were submitted, pursuant to 10CFR50.12(a), for NRC approval.

If there are any questions, please advise.

Respectfully submitted, ALABAMA POWER COMPANY R. P. Mcdonald RPM /DHJ :ds t-D-T.S.4 cc: Mr. L. B. Long Dr. J. N. Grace Mr. E. A. Reeves Mr. W. H. Bradford