0CAN118706, Responds to Violations Noted in Insp Repts 50-313/87-14 & 50-368/87-14.Corrective Actions:Fire Protection Program Will Be Incorporated by 890731,per Generic Ltr 86-10

Responds to Violations Noted in Insp Repts 50-313/87-14 & 50-368/87-14.Corrective Actions:Fire Protection Program Will Be Incorporated by 890731,per Generic Ltr 86-10

ML20237A321
Person / Time
Site:	Arkansas Nuclear
Issue date:	11/30/1987
From:	James M. Levine ARKANSAS POWER & LIGHT CO.
To:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
0CAN118706, CAN118706, GL-83-33, GL-86-10, NUDOCS 8712140403
Download: ML20237A321 (6)

Text

._ _ -__

$Ok$'j i

Dm 3 ggr  !

ARKANSAS POWER & LIGHT COMPANY

- Y November 30, 1987 l

l l

OCAN118706 L. J. Callan, Director Division of Reactor Projects U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011

SUBJECT:

Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313/50-368 License No. DPR-51 and NPF-6 Response to Inspection Report 50-313/87-14 and 50-368/87-14

Dear Mr. Callan:

Pursuant to the provisions of 10CFR2.201, a response to deviation 313-368/8714-02 identified in the subject inspection report is submitted. This completes the response to this inspection report as discussed in our letter of October 30, 1987 (BCAN108709).

Sincerely N@Jnh

,,d c.ecutive Director, j' ANO Site Operations JML: PLM: dm attachment cc w/att: U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 8712140403 871130 '

PDR ADOCK 05000313 G PDR l[-~ O f MM MEMBER MIDDLE SOUTH UTILITIES SwSTEM }{!

_ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . . _ _ . . _ _ _ . _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ ._ _ _ _ _ _ _ _ ___.)

, , , Attachment page 1 NOTICE OF DEVIATION A. The licensee committed to establishing and maintaining a fire protection program under the guidelines of Appendix A to BTP-APCSB 9.5-1. Under this program, the plant was divided into distinct fire areas isolated by fire-rated walls and floor /csiling assemblies which were to be surveillance tested under the provisions of the plant Technical Specifications.

In deviation from the above, the NRC inspector determined that certain fire barriers, such as portions of the wall and l

floor / ceiling surrounding the control room were not being surveillance tested per the Technical Specifications.

(313/8714-02, 368/8714-02)

RESPONSE TO DEVIATION 313/8714-02, 368/8714-02 AP&L agrees tnat certain fire barriers perviously designated as such, per our commitment to establish and maintain a fire protection program l under the guidelines of Appendix A to BTP-APCSB 9.5-1, are not presently being surveilled per the Technical Specifications. However, as further discussed in this response, AP&L does not agree that these barriers continue to require surveillance per Technical Specifications.

AP&L maintains cnd surveils penetration fire barriers for designated fire areas defined as such per the requirements of 10CFR50.48 and Appendix R.

The current designated i' ire area boundaries resulted from a reanalysis performed in accordance with the NRC staff interpretation provided in Generic Letter 83-33 and provide a level of safety beyond the earlier requirements. The events prior and subsequent to issuance of this generic letter are discussed below.

The basis for certain commitments included in the fire protection program previous to Appendix R was provided in the SERs, Section 2.0, that were issued fo~t ANO-1 and ANO-2 as follows:

"The overall objectives of the fire protection program enbodied in BTP-APCSB 9.5-1 and Appendix A, are to:

(1) reduce the likelihood of occurrence of fires; (2) promptly detect and extinguish fires if they occur; (3) maintain the capability to safety shut down the plant if fires occur; and (4) prevent the release of a significant amount of radioactive material if fires occur."

The original Fire Hazards Analysis for ANO designated certain rooms as " fire areas." These were reviewed against Appendix A to BTP APCSB 9.5-1 and were either in conformance with or met objectives of the NRC guidance. The barriers surrounding these " fire areas" were surveilled per the Technical Specifications that were issued for fire protection features approved in the NRC Fim Protection Safety Evaluation Reports issued August 22, 1978, and August 30, 1978, for ANO-1 and ANO-2 respectively.

Attachment page 2 On November 18, 1980, the NRC published the Fire Protection Rule, 10CFR50.48, and the requirements for implementation of that rule, Appendix R to 10CFR50. The effective date of the regulation was February 17, 1981. The separation requirements of Appendix R III.G provide guidance as to acceptable means of assuring that item (3) and (4) of the BTP objectives listed above are adequately addressed, and if not, III.L provides guidance as to alternate or dedicated shutdown capability requirements.

In a March 19, 1981 letter (0CAN038106), AP&L requested exemption from the requirements of Sections III.G and III.L of Appendix R, on the basis that previous modifications conducted in accordance with the 1978 SERs assured the protection of the public health and safety, and additional modifications in accordance with Appendix R would not increase that protection significantly. By letter (0CNA058202) dated May 10, 1982, the NRC granted AP&L an extension to July 1, 1982, to submit specific exemption requests and proposed modifications pertaining to the requirements of 10CFR50.48 and Appendix R.

On July 1, 1982 (OCAN078202), AP&L submitted the results of its Appendix R compliance review and specific exemption requests. This submittal included identification of designated fire areas and fire zones. Subsequently, on March 1,1983, the Nuclear Utility Fire Protection Group (NUFPG) met with several NRC staff members to discuss certain generic issues. As a result of that meeting, AP&L determined that it would be necessary to reanalyze ANO to determine the extent of compliance with the staff's interpretations of the requirements of Section III.G of Appendix R. This reanalysis would subsequently change the designated " fire areas" to conform with this NRC guidance presented in the March 1, 1983, meeting and later issued to all utilities in Generic Letter 83-33. AP&L requested a schedular exemption for all barriers on March 28, 1983 (0CAN038322), in order to perform the reanalysis on a " fire area" basis. The following is the NRC's guidance regarding " Fire Areas" as described in Generic Letter 83-33:

2. Fire Areas Staff Position: Section III.G of Appendix R sets forth the requirement for fire protection for safe shutdown capability on the basis of fire areas.

A fire area is defined as that portion of a building or plant that is separated from other areas by boundary fire barriers (walls, floors and ceilings with any openings or penetrations protected with seals or closures having a fire resistance rating equal to that required of the barrier). Open stairwells and hatchways in ceilings and floors are not fire area boundaries.

1 For boundary fire barriers, using walls, floors, ceilings, dampers, doors, etc., existing prior to Appendix R, the rating required of a boundary fire

, , , , Attachment page 3 l

barrier is based on the guidance in Appendi.x A to BTP-APCSB 9.5-1; i.e., the rating of the barrier or ,

boundary must exceed with margin the fire loading l in the area and need not necessarily be a 3-hour rated boundary unless the fire loading warrants such a boundary. For modifications which involve the installation of new boundary fire barriers pursuant to Section III.G.2.a, the fire rating of such boundaries must be three hours, or an exemption must be justified and requested.

The evaluations by some licensees made prior to Appendix R were based on fire zones which do not meet the strict definition of fire areas clarified above. In some cases, the separation of redundant trains under consideration within the " fire zone boundaries" and the separation between fire zones does not comply with the. separation, i.e., barrier or distance, requirements of Appendix R. Such configurations need to be evaluated under the exemption process.

The fire protection requirements cre intended to provide reasonable assurance that at least one safe shutdown devision is free of fire damage after a postulated fire in any fire area. The definition of " fire areas," noted above, is predicated on sound fire protection engineering principles as they apply to limiting the fire and I fire suppressant damage to redundant shutdown equipment and cables. Fire areas defined by i non physical boundaries, such as " logical divisions or equipment groupings," may not necessarily restrict fire and smoke spread, and do not necessarily provide reasonable assurance that the limits of fire or fire suppressant damage to shutdown systems have been defined. j Based on this NRC guidance, AP&L applied the new definition of " fire l area" to the reanalysis of fire barriers providing separation of these l

" fire areas." This resulted in the predesignation of barriers into

" Tech-Spec Walls (Floors)" or "Non-Tech-Spec Walls (Floors)" as depicted on the FIRE AREA AND ZONE BOUNDARIES drawings attached to the reanalysis submitted August 15, 1984, which represented the effort to provide separation of safety-related systems, structures, and equipment providing the capability to shut down the reactor and maintain it in a safe .

shutdown condition, or to provide alternate shutdown for areas that could I not be modified to provide such separation. Fire barrier upgrades, penetration sealing and qualification testing, engineering analysis and walkdowns, drawing revisions, procedure changes, and other efforts l associated with the reanalysis resulted in costs in excess of seven  !

million dollars, i

, ., o Attachment page 4-i The technical specifications require penetration fire barriers protecting safety related areas to be functional and to be surveilled to assure this functionality is maintained. The surveillance procedures were initially j revised to comply with the reanalysis in May, 1983, on the assumption that to delay could result in noncompliance with the fire protection requirements. In a June 17, 1983 letter (BCNA068312), the NRC recognized that AP&L was in the process of performing a reanalysis based on our understanding of the staff position regarding fire barriers and that the "new analysis will determine the necessary fire barriers."

In a June 21, 1983 letter (2CNA068302), the NRC requested AP&L to submit a license amendment request for ANO-2 to delete or modify the fire protection related license conditions (these were not imposed during licensing of ANO-1). AP&L submitted the amendment request August 1, 1983 (2CAN088302), stating that "this amendment is desired in order to eliminate continuing confusion and conflict between the License and requirements per 10CFR50 Appendix R." In the justification for the amendment, AP&L states that "10CFR50.48 and 10CFR50 Appendix R require AP&L to implement a more rigorous fire protection program consistent with those regulations." This amendment request was in accordance with our understanding of the NRC requirements and the interpretations provided by the NRC staff.

The current fire barrier surveillance, performed to meet the requirements of the Technical Specifications, comply with the current fire protection program guidance. The barriers previously surveilled under the Appendix A to BTP-ASCB 9.5-1 requirements which are not surveilled under the current programs do not meet the definition of a fire area boundary under the guidance provided by the NRC. Based on this understanding, AP&L believes that we are not in deviation of commitments due to these commitments being superseded by the later guidance provided by the NRC and that the protection afforded under our current program provides adequate safety. The specific barriers cited in the deviation are no longer " fire area" boundaries, and not included in the technical specification surveillance of " fire area" barriers.

The apparent misunderstanding between AP&L and the NRC as to the separation requirements for fire protection, including the programs prior to and following the issuance of 10CFR50.48 and Appendix R, resulted in the citing of this deviation. To clarify AP&L's commitments, we intend to incorporate the fire protection program, including the fire hazards analysis, by reference into the Safety Analysis Report for our facilities ,

by July 31, 1989. This will be in accordance with the guidance provided 1 in Generic Letter 86-10. This will result in a standard license l condition and deletion of the technical specifications regarding fire protection. This will not, however, result in any degradation of the ,

fire protection program for ANO. I The current " fire area" boundaries meet the separation requirements M Appendix R. Exemption requests have been submitted for cases where separstion requirements could not be met, or alternate shutdown has been provided. Additionally, the " area" designations consider l

1

, , , , Attachment page 5 l

l the comprehensive cable analyses performed to determine where separation l of redundant cables as well as equipment was required. These extensive analyses provided a level of safety beyond that required for BTP 9.5-1 Appendix A reviews. It is the aspect of the separation criteria of 1 Appendix R that is an added measure of plant safety and provides greater protection of the health and safety of the public.

l 1

l l

I 1

_ _ - ___ _ _ -_ ___- ._ _ i