ML033381050

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Emergency Diesel Generator Access Corridor Fire Zone 98-J ANO Appendix R Position Paper
ML033381050
Person / Time
Site: Arkansas Nuclear  Entergy icon.png
Issue date: 11/24/2003
From:
- No Known Affiliation
To:
Office of Nuclear Reactor Regulation
References
FOIA/PA-2003-0358
Download: ML033381050 (40)
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Text

  • ANO Appendix R Position Psper BACKGROUND During the 2001 Fir Protction Trieanial audit, the NRC inspectors expressed a conero twdi go sepaation of safe shutdown ciruits in Fire Zone 98-J. Specifically, the inspectors Od *At In NM of providing passive fir barriers on rd tin conduits, ANO crudits Wkng manual actions so cozl
  • associated safe shutdown components MANUAL ACTIONS In the late 1970's, ANO made upgrades to the existing fire protection features in an p to _ t guidance spcifecd by Appendix A to the Auxiliary Power Conversion Systems BrM* (APCSD) N-P Techical Position 9.5-1 (BIP 9.5-I). In doing so the staff posed numerous questiw conoaub *A capability to achieve safe shutdown. Some examples of the cowrrespondence include:
  • NRC letter dated 02-22.77, Item 48 posed a question concerning the manual peaa cifvalves.

ANO letter dated 04-12-78. responded to Item 48 (i.e. manual operation of valv).

. NRC letter daW 04-13-78, Items 82 and 92 mqucstcd information conccmring timc xvaib to perform manual operations.

  • ANO letter dated 04-26-78, responded to Items 82 and 92. Regrettably, the avalable er d microfllm copies of the response did not include Item 92, whidch dealt specifically with Zone W.

ANO will be attempting to obtain a copy of this page from the Public Document room.

  • ANO submittal on Appendix R compliance dated 07-01-82. The introduction offt¢ A provided the methodology for compilance analysis. Step 6 took credit for mammal Pm.eif equipment. Step 7 evaluated the remaining redundancies with respect to Section m.u Section 2 of the submittal discussed zones that comply with Appendix R and qcity Om Wter manual actions may be required. Section 4 of the submittal discusses Zone 99-i madSt anciewl exempion request The discussion notes tha multiple red train cables are located In he carrir.

primarily associated with the red DC equipment. The discussion notes that the only circts requi.d to achieve safe shutdown are associated with the RS panels (i.e. nstrumentation power) ad will be protected by a 1ou rated barricr.

  • NRC (via Brookhavcn) poses questions in a mcting (08-2542) concerning mamml Actium rvqob so achievc safe shutdown.
  • ANO letter dated 10-05-82 formally responded to the NRC questions of 08-254 2. The reWas" addressed manual actions in sceral Unit I zones. Zone 98-J was not included bc at On de,_

nl Zone 984 had a pending exemption request, whereas the question was directed ward tse zones in which compliance with Appendix R had been Identified in the 07.01-82 submittal.

In addition to the above correspondence, the Fire Hazards Analysis (SAR section Appendix 9B) die k criteria for utilization of manual actions, in lieu of remote control.

Also. Regulatory Guide 1.198, Section 5.3 sates One success path of equipment neocsuy to aci h standby (PWR) or hot shutdown (BWR) form either the control room or encrgency conircl muvimould b maintained free of firc damage by a single fre, Including an exposure fire. Manual operati o VA.

switches, and circuitbreakers is allowed to operate equipment and isolate systems and is nd coridered a repair."

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ACTIONS REQUIRED IN 8-1 Assuming that the Suppression system InZone 98-1 fals to operate nd that all red buim vw y sustain damage, the folloiing list of manual actions would be required to be performed wl 0 10bow-.

Manually align Service Water (SW) to the emergency diesl generator (EDG) - Reinwc con" t W pump and the EDGjacket coolerisolation valve could be affoct SW flow to the HDOJ wl_

be restored within 7 minutes to prevent overheating and mechanical dam. CV3W6 s c imSo EDO room and is acessible within this tinefrane. The SW pump can be started at te A3 mwtc by manually closing the associated breaker. Local operation of the breaker can be performud or S minutes. One person would be dispatched to the EDG room, whereas another operatr wo pmc.e Ao the A3 switchgear room. In the event SW flow cannot be readily restored, the EDO Ga be " dowt from the Control Room. Electrical power is not required until Emergency Feedwater (FW) or l inventory make-up is required. Consequently, sifficient time, access and personnel are nvollal to manually control SW components prior IDrestarting the EDG. Afollow-up action wouW be so il Ow ACW line (via CV3643) in the event a single SW pump is providing flow to both Loop I Lo n.

Manual dart of EDG - Control cables that voild cause the EDO to spuriously trip Mdor ba to OWL T control cirmit for the EDG output breaker could also be affected. The EDG can be in a 'No DC -

Override mode. Starting the EDO in this mode will elminate the possibility of a qsriow upW cisag the EDG totrip. One person would be dispatched to the EDG room whereas anolter _Nr i procod to the A3 switchgear room to manually control the output breaker. To ensur the ber ot spuriously trip, isolation of DC powcr (locally at the switchgear) will also be rquired. As mete wvs, electrical power is not required until either EFW or RCS make-up is required.. Consequensly, 9W lak time, access and personnel arc available to perform a local manual start of the dieel.

Manually align EFW - Control cables for the FW discharge and suvilon valves as well a Fur e wxr driven EPW pump could be affected. Prior to starting the EFW pump, the suction vilvs v be deenergized In their pre-fire position by opening the associated breakers Inthe red electriW eq~onwx room. Normally closed flow control valves CV2646 and CV2648 can be deenergized (i.e. thd opn) by operating the disconnect switch in the Lower South lectrcal penetration room. the diabW yak" (CV2626 and CV2670) spuriously close, these valves can be deenergized in the red elect*W e9_pmsM room and manually throttled in the piping penetration rooms. Once the required vahlv verifled I. be in the correct position, P7B can be manually started at the A3 switchgear. One person infld Igh the valves and close the breaker ror P7B, while an addiLional operator locally verifies vahe pi is 0 Auxiliary building. hese actions are similar to those performed during Alternate Shulti (AID) mdmm readily achievable within 20 minutes. With the RCPs running, EFW is required to be ra" in approxmately 30 minutes. However, if the RCPs ar tripped, EFW will not be required foe at 1 50 minutes. Consequently. sufficient time, access and personnel are available to perform tse imem actions.

Manually start make-up pump*- Assuming electrical power is available, Letdown iolati is ac c.v I1 from the Control Room. However, in the event that the EDO does not function, the hoLsti. vaiw cU be manually operated. With prompt isolation (i.c. within 4 minutes) of Letdown, invenoicy _on wi nd be nessary for at ast 40 minutes and will be related to the cooldown rate and the amocasd Aridmp of the RCS. In the event remote control of the make-up pump and associated a rdliay ihe mlp in affectod, the pumps can be started by closing the breakers In the A3 swtchgear orn. In h at wt the swing pump is being utilized, the disconnect switch for P64B may require operaiom The uw is bn.d on elevation 317' of the auxiliary building. Although sufficient time is available for a sle ro to perform the required nanual actions, conservatively, it Isassumed that two operators ilU beWtizsu oW to operate the breakers and one to operate the disconnect switch. Sufficient time, access, mid j s available to perform these manual actions.

The remaining manual actions need not be performed within the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of the event and ar typicly not required to maintain hot shutdown.

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In sumnay, two operators can perform the actions required to achicm sae shutdown fr Zo9eu1. Om operator will be stationed in the A3 switchgear room, with a brief excurion to the red ecil cpnt roomllower south eleciical penetration Toom. Operator #2 will be stationed In the usoliybinas manually start the EDG, vanuhlly open he SW valve to the EDG, imanilly align Ow EW _

manually operate the P64B disconnect siitch (as required), per the direction of the SM ?.. Mw smmation of these actions are much les intensive than those specified in the ASD pncowe. sU actions in the ASD are accomplished within 25 minutes. The manual actions specifte for Z WIJ w not required to be completed for at least 40 minutes.

CONCLUSION From the official correspondence, It is clear that manual operstion of safe shutdown epipmn Wu considered a viable method for achieving safe shutdown in both the pre- and post-Appadix R Pri.om tho 1982 submittal, it is clear that manual operation of components was utlized as a mc~wl IF1Ui n

.prior to evaluating the need for pasive fire barriers. From the discussion of the nu Wsedaio, k ts dw that the manual actions can be performed with personnel that are not assigned to the fir bdet dL a timely manuncr. Therefore, with the exception of the circuitry associated with RS 1 and ltS nla, t ed train cables arc required to function in order to achieve safe shutdolwn and thus do not royt the installation of a passivc fire barrier.

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February 22, 197 Docket Nos. 50--313, 50-368 . O 2'3O 7,2&iOitnf Arkansa IPowemr J&Littht CmDnn

_ * - -~ a ATTN; Mr. . . Phillips

'Senior Vice President Production, Transmission and Engineering

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Sixth and Pine Streets Pine Bluff, Arkansas 71601 Gentlemen:

RE: 'FIRE PROTECTION EVALUATION FOR ARKANSAS NUCLEAR ONE -

UNIT NOS. 1 AND 2 (ANO-1; ANO-2)

Your letter of January 7, 1977, suggested that the ANO-l fire protection

s evaluation is unique in that this evaluation will require mch Suo time to perform than proposed by licensees of other operating reactors.

We do not understand this position and cannot accept It. We canot hlp but believe that if you assign the same high priority effort to this

-evaluation that other licensees have assigned, you should be able to A, complete it in about the same time as other licensees. Over, because we did not provide the attached request for addition&l Information concerning ANO-1 by December 17, 1976, as anticipated in our ltter of December 3, 1976, we will grant an extension until July 29, 1977, as

-- stated in your letter, to complete this task. However, we fel vy strongly that the analysis should not require any further extaeon nd that every reasonable effort should be taken by your staff to lmoue C- this schedule.

The attached request for additional information is in additioa to that provided as Enclosure 2 to our October 2 1976 letter. You should respond to both requests by July 29, 1977. Additionally, w~wre applicable, your submittal for ANO-2 should answer these same questions.

Sincerely, Karl R. Goller, Assistant Director for Operating Rectors Division of Operating Rsactors EncTosure:

Request for Additional Information 9 aBed

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47 Provide the following information which was omitted in your initial Item 4(h) Page 6 topic - Self contained Breathing Apparatus.

Item 3(e) Page 10 topic - Hose nozzles Item E 3) & (.4) Page 16 topic - Hazardous Chemicals and Materials Containing RadioactiY ty Item D.l(b) Page 12 topic - Refueling and Maintenance Item 6 Page 7 topic - Administration Procedures.

  • . 8. Describe the provisions for manually mnanipulain safe shutdown and describe whether these valves are olsrequ ed for accessible during shutdown operations.

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NHeLPI N A1L AKANANFLE APKANSA8 POWER & LIGHT COMPANY t.a mOt(5 LITTLE "NK AtKAW3AU ?3UO . W?-S April 12, 1978 lDirector of Nuclear Reactor Regulation ATTI: Mr. J. F. tolz, Chief Light Water Reactors Branch 1 FSAR UPDATE REVIEW U. S. Nuclear Regulatory Caiaiton ff Washington, U. C. 20555 Rev. ByZ> Dat Director of Nuclear Reactor Pegulation Aplicable: Yes ATTX: Mr. R. W. Raid, Chief Operating Reactor Branch 4 U. S. Ituclear Regulatory Commission.

Wauhington, D. C. 20555

Subject:

Responve to Fire Protection Questions (Filet 1510, . 2040. Z-1510. 2-Z040) entlemen:

- Attached please find responses to Staff Itire Protection Quowtloua. All questions and staff positions formally received have nw b reonded to vith the exception of 3c and 39. These rexponses are being layed due to the amount of analysis necessary and will be provided within the next few dayn.

Also. find attached Amendment 1 to our Fire Hazards Analysts uporctlg Xnformation oubuitted February 28, 1978.

For tose reapoxes requiring .dralingw, 4 copies of the drseim * -

been supplied. Also .4 copies of drawing E669 which were' tted frm our March 3, 1978, letter ar. attached.

Very truly yours, Daniel R. William Hanager, Licensing DHW:JTs:nf Attechmnt tAX P*VINSF, INVETOM OWNED 4MGStM MICOLU SOUtHUT41LITMO SW'Ct-II JesTonN sOJUJU pw4.ul -

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Item 48 Describe the provisions for manually manipulating valves realted for safe shutdown and describe whether these valves are accessibla dring shutdown operations.

Response: (AVO-1&2)

The need to be able to manually operate valves required for safe -astdown which could possibly be affected by a fire has been considered as part of our ANO-1 and ANO-2 "Fire Hazards Analysis" studies. For ech fire zone within either unit, the capability of a fire to cause loss of power or control to valves required for safe shutdown was determined ad is al cases, it was verified that the affected valves could be imevally operated.

As indicated by our acceptance riteria detailed in the "Fire -azards Aal-ysst," all cases were analyzed to verify accessibility, capability for -

  • 4 - manual operation, and time available before manual operation is required.

No credit was taken for manual operation of any valve not meeting the above acceptance criteria.

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,ee..Olt Irex -' Lo UNITEo STATES 2adv- 7 -Al7 4 aCLEUCLEAFt REGULATORY COMMISSION Ain 6:91Mif X air [ '/l} t WASHINGTON, 0. C. 20555 X,Ie /O a-,;,

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B y April 13, 1978

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Dockets Nos.: 50-313 and 50-368 Arkansas Power & Light Compani ATTN: Mr. William Cavanaugh, III FI Executive Director, Generation and Construction Department P. O.-Box 551 Little Rock, Arkansas 72203 Gentl emen:

Enclosed (Enclosures 1 and 2) are additional requests for nforatlon and staff positions that have been developed as a result of our review of the fire protection program for Arkansas Nuclear One - Units Hos.

1 and 2 (ANO-1/2). Enclosure 3 identifies regulatory staff positions resulting from our review of the administrative control for fire protection for ANO-1/2.

With respect to the staff positions, you should provide a statemnt that you will inplement the position as stated or provide a ustification for your objection and submit an alternate solution to the concern In either case, you are requested to provide a description of the resulting proposed modification or method.

To maintain our review schedule for your application for an operating license for ANO-2, we will need your response by April 28,' 1978. It is requested that the response for ANO-1 also be provided by April 28, 1978.

If developnent of the response for ANO-2 will cause a delay in submittal of the response for ANO-1, you are requested to submit the response for ANO-1 first.

Sincerely, 6- I. /  : /

Robert. W. Reid, Chief Operating Reactors Branch #4 Division of Operating Reactors John F. tcolz, Chief Light Water Reactor Branch #1 Division of Project Managenwnt q

Enclosures and cc:

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(ANO-2 cribe the time allowable to manually orate yalvs which may be affected by fires in the following areas.

Describe the criteria used to establish the allowable time.

2032-K, item #7 2111-T, 8

\> 2073-DD, 1, 15)

_,[ { ~~~~2084-DD, 3&4 I_ ~~~~~~~2081-HH, 3 (AN-2) 8 n. e how a fuel oil line break would be detected so that fuel pumps may be stopped.

(ANO-2) 84. Zone 20974. Acceptance criterion 6 is used for this Or zone indicating that affected systems are not required for safe shutdown. However, a fire in this zone may affect redundant battery chargers.

I Describe how loss of the battery chargers on faults on the associated cables is precluded from affecting the

  • I batteries.

(ANO-2) 85. Zone 2100-Z, item 2.0. Identify those systems which would lose cooling water for a fire affecting valves 2CV1425-1 and 2CV1427-2.

(ANO-2) 86. Zone 2073-DD, item 8. Describe why the shutdown cooling suction valves are not required for safe shutdown. Identify the location of these valves.

(ANO-l&2) 87. Your response to position PF.5 states that cable pene-tration firestop tests will be performed. Provide the results of these tests to demonstrate that our positinn I is met. Results of tests performed should cover Unit 1 and Unit 2 firestop designs.

(ANO-2) 88. Describe how penetrations of fire barriers are sealed including doorway, ventilation duct, and electrical cable penetrations. It is our position that these should be three-hour fire-rated.

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U;-JTIQ 01 II (ANO-2) 89. Zone 2055-J. Describe why the ECCS pump room coolers are not required for the operation of the high pressure and low pressure injection pumps in these roows en these pumps are used to achieve safe shutdown conditions.

(ANO-2) 90. Zone 2010-LL. Describe the redundant equipment that may be affected by fires in this zone. The equipmt described in the "Redundant Safety Circuitry" section is only from one division.

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(AN0-2) 91. Zone 2150-C. Describe why the coolers are not required

-but the condensers are required for the ontrol room L. (AN-)/92. Describe the time allowable to manually operate vlyes 0

t ~149-E, item i3, r

98-J, 07,8 (AND-l) 93. Identify the quantity of lbe oil in the service water pumps at the Unit I Intake structure.

(ANO-1) 94. Response 57 does not substantiate the conclusion that a hot short affecting associated circuits cannot effect more than one safety division, According to the Informtion provided, it appears that itwas pemissable to route an associated circuit, connected to one safety division, in a non-safety related raceway. Redundant safety equipment could then be affected by a fire that involves this non-safety tray and a non-safety or safety tray con-taining the associated circuit of the corresponding redundant equipment. Describe any separation criteria which preclude such an event. Additionally, describe V any solation devices which would prevent a hot short in associated circuits from affecting operation of the safety equipment to which the associated circuit Is connected.

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L;C/4,8< 9 C"HRONOLOGIcAXL H4ELPING OUILO AF1K A:IK ANSAS POWER & LIGHT COM P0 U001xbb LYIi. ROCK AAKANSAR7220 BC r April 26, 1978 Irk +/- .

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t)2~04 829 02831855 ARKANS ?s ?.LIGHT TECH. L Ei.'d. SEkRvCEJ Director of uclear Reactor ReguLation ATTN: Mr. R. W. Reid, Chief Operating Reactors ranch 4 Hr. J. F. Stolz, Chief

!

  • Light Water Reactor. Dranch 1 U. S. Nuclear Regulatory Cotission Washington, D. C. 20555

Subject:

Arkansas Nuclear One-Units 1 S 2 Dockets 50-313 50-34 License o. DPR-51

-w Responae to Fire Protectim Questions & Staff Positions (File: 1510, 2-1510)

Gcntlemen:

In response to your letter of April 13, 1978, the following I attsched:

1. Response to Questions 77-96
2. Response to Staff Positions FF.9 - PF.17 and PF.1Y - 25
3. Response to Staff Positions concerning Administrativ Controls tin the form of a revised Fire Protection P1an)
4. Response to verbal questions received 4/21/78.

For those responses requiring reporta and/or drawinps, a linit*d mber of the reports and/or drawings i provided.

This letter copletes our response to all Fire rotection qusttons received to date.

Very truly yours, Daniele. cWnlliarn Ha~nage r, Li cens ing I DINW;JTE: t Attachment F^ PAY In *>lst';<.' *  :- t  : , ..- -: - *. *. . - . ... ......

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ITEM 82 Describe the time allowable to anually operate valves hick mt b (

affected by fres n the following areas. Describe the crltarla g" to establ1sh the allowable timc.

2032-K, item 7 2111-T, 8 2073-DD, 11, 15 2084-DD, 3&4 2081-1H1 3 RESPONSE ANO-2) 2032-K. Item 7 - the acceptance criteria was no's 5 and 6. Credit for acceptance criteria No. 7 was not taken.

2111-T Item 8 - lights in the control room are provided by the coetrol switch for the cooler heat exchanger outlet valves to indicate whether they are open or closed. If the valves do not open w9O the Alsels start, the operator will have three (3) minutes (Sea #M: Sectios 9.5.5.3) in which to manually open the valves. The cooler Uet *zbin#er outlet valves are located in.fire zone 2073-DD at El. 354'-0" ed three minutes will be more than sufficient time for operator etle.

2073-DD tem ll - acceptance criteria #6 can be applied to this ites.

If the service water outfall control valve were closed *ud without power, then the plant can utilize the emergency cooling pond.

2073-DD Item 15 - the power cables for the E discharge valves are routed in different areas of this ire zone. If a fire wra to occur,.

at least one or more of these valves would be able to oerate atoaeically before the fire could affect. them. The operator will have plenty of time to manually open other EFW discharge valves that have lost power since feedwater is being provided to one or both ataa* geserators.

3ecausu of the distances that a fire would have to trasvl and the. lack of a combustible bridge in ome ases, it is good IJg(Ie3* Judgmet that automatic operation of one or more valves ill occur before the power to the valves i threatened by a fire.

2084-DD Item t3 - See response to 2111-T Item 18 above.

2081-IIH Item 03 - power cables are in conduits and the heat lad i. thiu zone is very low (83 TU/ft 2 )'. As with fire zone 2073-DD Item #15 above, if a fire should occur, there would be a sufficient amount of time for the EJ discharge valves to automatically operate and for operators to open any valve manually that might have been affected imedately by the fire.

[Iet a~ed 'VEIVIZILeVZ eW~O e8ed JOUTonN seis psun :Ail lu

ARKANSAS POWER & LIGHT COMPANY POSTOFFICE BOX O51 UrLE 1QAOC S KANSASn72W% (!OI 371..

July 1, 1982 0CAN078202 Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, . C. 20555

SUBJECT:

Arkansas Nuclear One - Units 1 & Z Docket No. 50-313 & 50-368 License No, DPR-51 & NPF-6 Results of Appendix R Compliance Ri Gentlemen:

As requested in your letter for ANO-1 (CNA058202) and your letter for ANO-2 (2CKA058203) both dated May 10, 1982, the following is previded.

The AO fire zones were reviewed for their compliance to OCFRSO.48 and 10CFRSO Appendix R. The review was structured to incorporate te recommendations, clarifications, and evaluation criteria of Gmric Letter 81-i2. Our submittal also considers the staff's positions and perspectives advanced in its discussions with the uclear Utility Fire Protection Group during the period of December 1981 to Parch 1. 2 and reflected in the Nuclear Utility Fire Protection Group's letter of March 16. 1982. to Richard H. Vollmer, Director, Division Engineering.

The attached report documents the results of this review and is formated as requested by the Generic Letter 81-12 clarifications. As rquested, an item by item response is provided for each applicable nformation request. Where appropriate, exemptions from 1CFR50.48 and OCFR50 Appendix R have been sought per 10CFRSO.48.C.6.

This letter and the attached report provides AP&L's complete response as requested by your two May 10, 1982, letters and is submitted n July 1, 1982. as requested. Five (5) copies of our submittal will be hand delivered to our AO-2 Project Manager on July 1, 1942, to aid in the staff's review.

AIL 8207O 0205 820701 )3 PR ADOCK 05000310 F PDR MEMSER OODLE SCUTH Ut1TIS SYSTEM

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I Our staff is available to discuss the enclosed report with you should any questions arise. Further, if the NRC staff detromnes that additional information is needed to assist in its review, AP& is prepared to furnish such information as expeditiously as is rasonably possible.

Subsequent to submitting the enclosed report, AP&L will ontinue its verification of the information provided to the staff. In the event that any clarification of the information contained in the rt is identifled, MPrtMii'provide such clarification as eXitiously as possible.

As required by OCFR50.48 and 1OCRFSO Appendix R AP&L will continu to evaluate and assure its compliance to these requiremnts. Any future.

actions necessary to assure the facilities meet the requiresents will be taken in a timely manner to continue compliance.

Very truly yours, John R. Marshall Manager. Licensing JRM:sc Attachment

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I A R K AN SAS N UC L E A R O UNITS 1 AND 2 10 CR 50 APPENOIX R FIRE PROTECTION REVIOE E

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______ _______ _____________________________ I.~~~~

  • . SECTION 1 i I INTRODUCTION l

{ Effective February 19, 1981, the Nuclear Reulatory Comisslon I I promulgated an amendment to Part 50 of the ode of Federal 14 lations j to add sstantial detail to the requirements for fire protectioa at I operating nuclear power plants. Appendix R and Part 50.4 provide requirements in several areas, particularly with respect to sepration 1 Iand protection of components required for safe shutdown as delieaW I in Section III.G of Appendix R. 50.48 required submittal of pis N I schedules by a certain date. Since this date did not allow AL I I sufficient time to complete the necessary reviews and carisons to I Aopendix.R 1. the-identificatiootf deviations, and the pearation of I I exemption requests,. an exemption to the response date was equested by I I AP&L. I

  • . r
  • - I By letters of Hay 10, 1982, to AP&L on AO-1 and ANO-2, the WC granted I I AP&L's request for exemption to the submittal schedule until July 1, 1 I 1982, and requested AP&L to submit certain information regarding plant I I areas that comply with Appendix R, those where modifications will be I 1 made to meet Appendix R, those where xemptions are being reqested and I I the basis for such requests, and provision of details related to an 1 alternate shutdown capability and associated circuits. I This report provides the results of a detailed review by A L to I I determine the extent of compliance with Appendix R and to provide the I I information requested by the NRC letters of May 10, 1962. This report I I is ntended to be fully responsive to the letters of May 10, 1962, and I I to contain the information necessary for staff review. A sumary table I I (Table 1.0) is included which indicates the status of all zones as I I resulting from this review. Fire zone locations for Units 1 and 2 are I
  • I indicated-fnf igurer 1 throubh 12.- The report isorganized so that the I fire zones for ANO-1 and ANO-2, as defined inAP&L's Fire Hazard I AnAlvsys.).. eferenced-by.-or-.Deember 20, 1977, letter submitted to I I NRC, may be placed in one of three categories: I I I
  • Zones Satisfing A ehdfx R - these are the fire zones found I to presently satisTy Appendix R (Section 2.0 of Report).

I P I *.I PAGE 1 of 14 5 !VuczJ VOOTn 5 9 J89TOflN svlii veiufl As xu Wts sBed ~'I9I.

G~d LI.6 vo-s-Tfnr

ARKANSAS NUCLEAR ONE.

UNITS 1 ANO 2 I 10 CFR 50 APPENDIX R FIRE PROTECTION EJP I I

I _~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

i * ~Zones That Will Satisf Appendix R FollovigNow i III I ese are zones a o not presenty sa will fully comply following modifications (Section 3.0 *p I Report)..

1 .I

  • 0Znes e uirinq Eemtion - these are ones that do not I , , . P~rsentLV cmplt., and w ere full compliance Is et a to I
be necessary to meet the intent of Appendix R. In 1t of these, modifications are proposed to improve fire protection for these zones, yet full compliance will not be ichievd (Section 4.0 of Report). I I . .... I Section 5.0 of this report, presents a request, and provid I justification for, an exemption, in specific cases, frem the sIdrul for Inmp!,ntetifn-oi4 wi catons as set forth in 1OCFSO.4(c).

I .I I The appendices to this report provide additional detail to clar fy or expand on information contained in Sections 30 or 40, &#d to provide the information requested by the May 10, 1982, letters. Appnix F provides info stu inad .

The detailed evaluation performed by AP&L to compart A0-1 ud N-2 to P the requirements of Appendix R contained several major tasks smarized as follows:

I1. The or-gi-na+ f4irv-E Tards Analysis was used as a basis for this review. Fire zones containing safe sutdmn cpoets I } and any redundancies thereof were identified.

I /

2. A separate evaluation of associated circuits was used to I identify circuits of concern. I
3. Modificaitions made to the plantuj subsequent to issuance of the originaW FHAlere reviewed and incorporated where 1 ) applicable.
4. As the definition of fire zones in the original HA did not I I require one boundaries of 3-hour fire rating, adjacent zones I as well as all zones within 20 feet of the zone in question I were considered.. Additional redundancies were identified by I } this comparison,
5. Additional redundancies identified in 4 above were evaluated I9 for their effects on safe shutdown capabilities. I PAGE 2 of 14 I" II I 14.11 I !iL:

.rB fL-q-Tnlr- !tRZLP7L.LL!JO1TleTnfisU .RATnsM ¢aiPo nrwia'n *

ARKANSAS NUCLEAR O..

I UNITS 1AND 2 I.

I 10 CFR 50 APPENDIX R FIRE PROTECTION RVIO I.

ml a~~~~~

l i

I I 6., In certain cases, credit for manual operation of equ int iI was taken if controls (and power for valves) could Pousil be damaged by a fire. Such credit was taken only if: 1 I

I a. the component to be operated is not located in t I I affected fire zone, although the cabla my be damgd by I I fire;

~ III b. sufficient time is available to perform the repired I II manual actions; and . I II I C. personnel are available, beyond the fire brige and I I minimum operations shift crew limitations, to perform I I the manual actions. I I

II 7. *-For-redundancies that were still identified as potential afe I shutdown concerns following the above review, specific (

I physical separation, barriers, intervening comwstibles, and I

I suppression systems were evaluated to determine compliance II with Section II.G of Appendix R. I III

8. u

~ed 1 ies-remainin asao n I concern following 7 above, alternative means for I accomplishing the necessary function was reviewed.

I

9. Required modifications were identified to bri zones nto.

CII full compliance, or to a level of fire protection safety judged equivalent to alternatives of Appendix R.

I I

10. Engineering design concepts for necessary alternate shtdown I capability were developed. I l
11. Necessary Exemption requests were prepared.
12. Speial consideration was given to the cold shutdown I requirements of Appendix R and are described in Appendix E to I th s report-.

- . ~~~~~~~

The evaluations described above were performed in accordance with the I criteria of appendix R, including: consideration of cable insulation I as combustible; taking no credit for cable coatings to act as a thermal I or radiant barrier to protect cables; and diverting primary rliance I from administrative controls to preclude fires or damage due to fires. I I

I.

PAGE 3 of 14

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lVIBL O6Bd !6t:6 to-S-Tnr

I~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

I R~A K A N S A S NU CL E A R NE I UNITS 1 AND 2 I 10 CFR 50 APPENDIX R FIRE PROTECTION REVIEW I

SECTION 2 ZONES SATISFYING APPENDIX R df the 143 fire zones analyzed for ANO Units 1 and 2,*100-of th_ wre determined to be in compliance with the requirements set forth in 10 CFR 50.48 and Appendix R to 10 CFR 50. The following is a listing, by unit, of each of those zones, by number and names with a brief statement of the basis for compliance.

,7' .. S?

P,.

PAGE 1 of 12 14161 eBed '6 t:6 o-q-in r !tRZL9ZL9ZLO-SeTnfia .IPQT:nu ca-iwic n-ain -m s&A

A R K A N SAS N U C LE A R ONE UNITS AND 2 10 CFR 50 APPENDIX R FIRE PROTECTION REVIEW I ~~~~~~~~UNIT ZONE NUMBER NAME BASIS FOR CPLINACE 1E North Emergency Diesel Contains no redwnat safety Generator Exhaust Fans (EL 386) equipment or cables nor associated circuit concerns.

1MHO3 Manhole between Auxiliary Contains no redundant safety Building and intake structure equipment or cables nor associated circuit concerns.

1MHO5 Manhole between Auxiliary Contains no redundant safety Building and intake structure equipment or cables nor associated circuit concerns.

10EE East Decay Heat Removal Contains no rdundant safety

), Pump Room (EL 317) equipment or cables nor associated circuit concerns.

104S Electrical Equipment Room Redundant safety system in (EL 368) zone not required for hot/cold shutdown.

105T South Lower Electrical Contains no redundint safety Penetration Room (EL 374'-6") .equipment or cables nor associated circuit concerns.

ilOL South Battery Room (EL 372) Contains no redundant safety equipment or cables nor associated circuit concerns.

115C Lube Oil Tank Room (EL 354). Contains no redundant safety equipment or cables nor associated circuit concerns.

12EE Tendon Gallery Access Area Contains no redundant safety (EL 317) equipment or cables nor associated circuit concerns.

120E Boric Acid Addition Tank Contains no redundant safety and Pump Room (EL 386) equipment or cables nor associated circuit concerns.

PAGE 2 of 12 fl

[bOZ aBed !OZ:6 10-9-Tnr I vet'/Ot 6Jo1eTnBeH JeTonN sgjuas Perrun :Ad 3u

AR KAN S AS NU C LEAR O NE

  • UtIITS AND 2 I 10 CFR S APPENDIX R FIRE PROTECTION REVI I J ~~~~~~

UNIT 1 (continued) I ZONE NUMBER NAME BASIS FOR COMPLIANCE 125E Laundry Room (EL 386) Contains no redundant safety equipment or tables nor associated circuit concerns.

14EE West Decay Heat Removal Redundant safety systems n Pump Room (EL 317) this zone not required for hot/cold shutdown.

1440 South Upper Electrical Contains no redundant safety Penetration Room (EL 386) equipment or cables nor associated circuit concerns.

,1 149E North U per Electrical Manual operation may be (EL 386) required for both hot and cold shutdown.

157B Chemical Addition Area Contains no redundant safety (EL 404) .equipment or cables nor associated circuit concerns.

1598 Spent Fuel Area (EL 404) Contains no redundant safety Iequipment or cables nor

.associated circuit concerns.

Clean Waste Receiver Tank Contains no redundant safety Area (EL 327) equipment or cables nor associated circuit concerns.

160B Computer Room (EL 404) Redundant safety systems in this zone not required for hot/cold shutdown.

I 161B Ventilation Equipment Area Contains no redundant safety (EL 404, 422) equipment or cables nor associated circuit concerns.

162A Stair No. 1 (EL 404 to 317) Contains no redundant safety equipment or cables nor associated circuit concerns.

PAGE 3 of 12

' 1£ZLeg~T";'"ow JTeaonN sOeMS pgiun :Ag u try tZ afed !oz:6 Wo-S-Tnr

I A RK A N S A S NUCLEAR ONE I UNITS 1 AND 2

-) I 10 CFR 50 APPENDIX R FIRE PROTECTION REVIEW I

I UNIT 1 (continued)

ZONE NUMBER NAME BASIS FOR CONWLIANCE 1638 Reactor Building Purge Room Contains no redundant safety (EL 404) equipment or cables nor associated circuit concerns.

167B Computer Transformer Room Redundant safety systems in (EL 404) this zone not required for hot/cold shutdown.

168B Transformer Room (EL 404) Contains no redundant safety equipment or cables nor associated circuit concerns.

170Z Steam Pipe Area (EL 404) Necessary manual operation

.V can be accoplishod for cold shutdown.

I, 187DD Dirty and Clean Lube Oil Contains no redundant safety Storage Tank Room (EL 335) equipment or cables nor associated circuit concerns.

197X Turbine Building (EL 335, 354 Contains no redundant safety 368) .equipment or cables nor

"'associated circuit concerns.

2E South Emergency Diesel Contains no redundant safety Generator Exhaust Fans equipment or cables nor (EL 386) associated circuit concerns.

2026Y Drumming Station (EL 335) Contains no redundant safety equipment or cables nor associated circuit concerns.

31Y Purification Demineralizer Contains no redundant safety Area (EL 335) equipment or cables nor associated circuit concerns.

PAGE 4 of 12 -aI IV/zaz used ' Z:6 10-9-Tnr 'VEZIUWL~Z0VIJoeTln69 J88TonN sSzvz9 PezTun :At vu

A R K AN S A S N U C L EA R NE UNITS 1 AND 2

-) 10 CFR 50 APPENDIX R FIRE PROTECTION REVIEW UNIT 1 (continued)

ZONE NUMBER NAME BASIS FOR CMIACE 38Y Emergency Feedwater Pump Area Hot shutdown may be ccw (EL 335) plished by fd and blod.

Cold shutdown my ruire-manual operation.

4EE General Access Area (EL 317) Contains no redundant safety equipment or cables nor associated circuit concerns.

46Y South Lower Piping Penetration Necessary manual operation Room (EL 335) for cold shutdown can be accompl i shed.

Penetration Ventilation Area

) 47Y (EL 335)

Necessary manual operation can be accomplished for cold shutdown.

67U Lab and Demineralizer Access Necessary manual opration of Area (EL 354) service water sluice gates cai be accomplished.

68P Tank Room (EL 368) I'A Necessary manual operation of service water sluice gates 1.

can be accoplishted.

75AA Boiler Room (EL 354) Contains no redundant safety equipment or cables nor associated circuit concerns.

76W Compressor Room (EL 354) Redundant safety systems in this zone not required for hot/cold shutdown.

77V South Uper Piping Penetration Redundant safety systems in Room (E 356) this zone not required for hot/cold shutdown.

PAGE 5 of 12 A)-

WUe a6ed  ! [Z:5 10-Ft-Tnr It:Z1CZtr 8Z JO1eTne JTON S9OISI DOOTUn :Aa 2u

I ~~A R .K A N S A S NU C L A R NE UNITS 1 AND 2 I . 10 CFR 50 APPENDIX R FIRE PROTECTION REVIEW I

I UNIT 1 (continued)

ZONE NUMBER NAME BASIS FOR COMLIMICE 78BB Gas Bottle Storage Area Contains no redundant safety (EL 357'-6") equipment or cables nor associated circuit concerns. I 79U North Upper Piping Penetration (EL 360)

Necessary manual operation of service water sluice gates can be accomplished. K 86G North Diesel Generator Room Contains no redundant safety (EL 369) equipment or cables nor associated circuit concerns.

87H South Diesel Generator Room Contains no redundant safety (EL 369) equipment or cables nor

)I associated circuit concerns.

88Q Communications Room (EL 374) Contains no redundant safety equipment or cables nor associated circuit concerns.

89P Controlled Access (EL 374) Contains no redundant safety equipment or cables nor associated cimcuit concerns.

950 North Battery Room (EL 372) Contains no redundant safety equipment or cables nor associated circuit concerns.

1121 Lower North Electrical Necessary manual operation ef Penetration Room (EL 373'6") service water sluice gates can be accomplished.

128E Controlled Access (EL 386) Necessary manual operation cn be accomplished for both hot and cold shutdown.

1.t PAGE 6 of 12 '-'

Wltz aBed !ze:6 W-9-W VE:LFZLPL!VdJO18Tnl69 JTonf saiPiQ naiTtun !vA

  • l~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

l UNITS 1 AND 2 I

I I UNIT 1 (continued)

ZONE NUMBER NAME BASIS FOR CLIA Diesel Fire Pump Room Contains no redundant safe*

equipment or cables roor associated circuit concerns.

2MHO1W Manhole Contains no redundant safety equipment or cables nor associated circuit concerns.

2MH02W Manhole Contains no r dundant safety equipment or cables nor associated circuit concerns.

2MH03W Manhole Contains no redundant safety equipment or cables nor associated circuit concerns.

201OLL Pump Area (EL 317) Redundant safety systems in this zone not required for hot/cold shutdown.

2011LL Tendon Gallery Access (EL 317) Redundant safety systems in this zone not required for

hot/cold shutdown.

2014LL Pump Area (El 317) Contains no redundant safety equipment or cables nor associated circuit concerns.

2019JJ Tank Room (EL 327) Contains no redundant safety equipment or cables nor associated circuit concerns.

20203J Tank Vault (EL 327) Contains no redundant safety equipment or cables nor associated circuit concerns.

2025JJ Pump Room (EL 329) Contains no redundant safety equipment or cables nor associated circuit concerns.

r. .

PAGE 7 of 12 I-q

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[qRlz 0a5 !t77: r sn- c-,rnr

I A RKA N S A S N U C L E AR 0 NE UNITS1l AND 2 -

) I 10 CFR 50 APPENDIX R FIRE PROTECTION REVIEW I I I I _ _

l l l 1 1UNIT I EXEMPTION DETAILS I l FIRE ZONE: 9 CORRIDOR EL. 372' l

'I .. I A. AREA DESCRIPTION I This zone is bounded by 3-hour fire rated barriers. The corridor l I is approximately 100 feet by 9 feet with a 12 foot ceiling; the I zone includes two small adjacent rooms containing safety related I D.C. equipment. The D.C. equipment rooms are not separated from I the corridor by a 3-hour fire barrier. This zone contains a large I amount of cable insulation in open cable trays and conduit, l gene d overhead. I

) l B. 51\FE SHUTDOWN C ILITY .1 This zone is predominantly of the green" or B" safety division, I althouh certain cables associated with the "red" or "A" division are also located in the corridor ortion of the tR. rho -Xad I cable5 in this zone are routed in conduit and are protM X I - associated with the "red" 1 D.C. equipment room. I I R I~~

I C. FIRE HAZARD ANALYSIS I I The in-situ combustibles in this zone are cable trays throughout I the corridor and one lightly loaded tray in the red D.C. ipasnt I I room Since the cables have been flame tested as describeUl I . appendix C, ignition would be difficult, and propagation slow. I Transient combustibles could be introduced into this zone for I I servicing electrical components in this zone or in the adjacent I battery room, or switchgear rooms; however the amount of such I I combustibles would be small. A more significant amount of I I combustible material could be introduced into this zone during an I 1 outage in performing maintenance of the diesel generator unit. I I The two diesel generator rooms are accessed from this corridor. I The maximum amount of combustible would be 55 gallons of lube oil I I for changing the diesel generator lube oil. However, such I movement of oil drums normally only occurs when the plant Is I I already shutdown and the diesel generator is out of service. I PAGE 22 of 52 It/ge aBeO !p7:ri n-C-TnrP !iC7PP71C;IIV1 sHJ.O-lP.Tniau JPIPTinlu C*wic1O nai-rin -An ia

- hgh.* . . .

A R KA N S A S N U C L E A R 0 NE I UNITS 1 AND 2 I

) 10 CFR 50 APPENDIX R FIRE PROTECTION REVIEW I

!!~~~~~~~~~~~~~~~~~~~~~~~~~~

This zone is not continuously manned, but is readily accessible, I and- be reached by the fire brigade within a fV _Minutes of a 1 The "red" division cabling located in the corridor that is I required for safe shudown will be wrapped in a 1-hour fire barrier. The circuits involved are the power supplies to the IS )

panels which are located in the control room. With the I suppression system in this area and the addition of the 1-hour I I 1 fire barrier, the corridor portion of this zone will comply with \

I t Appendix R.

l The separation of the "red" D.C. equipment from the remainder of I the corridor does not satisy appendix R. Figure 98 shows the I I location of the doorway to this room. Photographs illustrate the 1 I configuration of components in the area of this doorway. The I I ductwork passing into the room is thermally insulated; this I ventilation for the "red D.C. equipment room is only required for I I design accident basis heat loads over a long time period, and not for plant shutdown and cooldown due to a fire. Howver, the I doorway opening below the ductwork is required to allow for I exhaust air out of the "red" D.C. equipment room. l There are no pathways for transmitting fire between the corridor I I and the "red" D.C. equipment room. To prevent a fire in either I I area from affecting components in the adjacent area, the following I modifications will be made: l

1. Coat the cable trays in the corridor with a flaeo retardant I I coating where cable trays are within 5 feet of the doorway I opening, so these do not present an exposure hazard to cles I or equipment in the "red" D.C. equipment room. I
  • 1 2. Coat the cable trays in the "red" D.C. equipment room that are within 5 feet of the doorway openings, so these do not present .an exposure hazard to calbes in the corridor.
0. FIRE PROTECTION - EXISTING OR COMMITTED This zone is provided with extensive fire detection and suppression capability. Ionization type smoke detectors are provided at the ceiling level for alarm in the control room and for suppression system actuation. In addition line type heat detectors are located in each tray that also alarm in the control I _

PAGE 23 of 52

[LZz O~e,4 !Pr, Ln-C-Tnr LfL+

4 ePer7 I tW71I AdMDvn- *A - - 1- -

I I I R~~A V(A N SA N U C L E AR 0 N EI I UNITS I AND 2 I CFR 50 APPENDIX R FIRE PROTECTION RIEW

~~10

! I room and provide for suppression system actuation. The suppression sytem will activate on.a signal from any one smoke I detector and any one line detector. Actuation and alarm circuits are supervised.

The suppression system consists of numerous directional open head spray valves located along each tray at a spacing sufficient to provide coverage of the top surface of each cable tray. Since all the heads are open, the entire corridor area will be sprayed down l on suppression system actuation, including coverage of transient I combustibles that may be ignited. The spray system may also be manually actuated. Due to the potential for water damae ad the minimal cabling in the D.C. equipment room, the suppression system does not impinge on trays in the D.C. equipment rooms. I4ose 1 stations and portable extinguishers are located in this zone as I well as in certain adjacent areas for use by the fire rigade. I As noted above 1-hour fire barriers will be added to enclose those I cables associated with the RS panel power. I E. / O Following modifications described above, this zone will I substantially comply with Appendix R; however, two exemptions re requested for this zone:

1. Omission of a complete 3-hour fire barrier separating "redo D.C. equipment room from the corridor; and
2. Omission of sprinkler coverage over trays and equipm t in I the "red" D.C. equipment room. I The completion of the 3-hour fire barrier is not judged to be required since no cable trays provide a pathway for fire propagation between the "red" D.C. equipment room and the corridor I and due to the coating of cables in proximity to the doorway between these to areas; the extensive suppression coverage of the corridor, the sensitivity and effectiveness of the type'.

suppression system in the corridor and the capability to promptly detect fires and suppress them manually if required.

Sprinkler system coverage in the "red" D.C. equipment room would be detrimental to plant safety due to the potential for water damage to sensitive equipment. Additionally, coverage is not PAGE 24 of 52 WgeR Bed  ! b: :6 tO Tn r !t.P7I97LP;IL!W.lJn10 TnfAu .ARMTfnlni cmto- nfl-reirt l is

. ^., M-- . . . - .

AR KAN S AS N UC L E A R ONE UNITS 1 ANO 2.

) 10 CFR 50 APPENDIX R FIRE PROTECTION REVIEW l required due to: the minimal amount of combustible materiel in the room1 the separation from redundant cables in the corridor, the coating of cables in open trays in proximity to the dormy and the capability to promptly detect and suppress fires manualiy I in this zone.

With the present protection and changes that will ade, extent of I fire damage will be limited so that-at least one train of shutdown I capability is preserved.

  • 1 I'

1 -

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ZONJ E 98 DATE REVISION ARKANSAS POWER AND LIGHT COMPANY Irn I/A 1132 _

ARKANSAS NUCLEAR- ONE DRAWN:

- UNIT DEGION!

!tr',.p;,Ip7I !W.JnlprniaRu .Jp:rrnnm CANDID n-ratin -i mm1

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W. CAVAKAJ= -; .. .1*

J. CRIPFPI T. IlcORt UNITED STATES l LICLEAnR EQULATORY CO.MISSION J. HAM1 wAlm4114UO4. C C V%"

ANDCC D-AMER Aust 26, 1982.

O. IHSP.RDI

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SIrltAMll (Hmc I

4% O 3ha F; Stolz, Chief. Operating Reactors reed.

HEMORMDUM FOR: JtM SI'SS 14 Gdy S. Vtss1ng, Pject Manager, Opcrattfl FROM: Lt1 CIN FORTHCOMHG MEETItG WITH ARIASAS OER tEMS tflt _N1 a -

SU8JECT: CNCERNIKG ALIERNATE SAFE SHUTDOWN APPENDIX I August 31, 1982, 7T.esdUy I

Time Date: 10:00 a.m. - 4:00 p.m.

6W Maryland tHational Bank 9911dils oD '3; lwcation: ethesda, o 1)

.S .

To disczs questions (ad" s:.

Purpose:

concerning the altwrne means for A-1 & 2

.I NRC-GW Vissing, Charla I W 6I Requts ted PArt5ctpants: ZJan Stevens, Vince Paies

-.APL-Larry Prscale, Ted te Other-John TaylorBNI i-"

-M.George, TEM g S. Y~ssiny;in_

Operating ctors t Division of Licensing 35?9

Enclosure:

1. Qestions
  • '*i.-** *.i If .5....

54

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cc w/enelosure: I..~-j

  • L

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CA.

ARKANSAS NU1CLEAR ONE UNITS I and 2 NL Ouestions/Jnforz'otifn ReQuests on Lcensee's 7/118 Ssttel

1. The 1icensee should acrine the systems required to bring the plo to bth hot and cold hutdown conditions. This ncludes f1l rquited m etal and lectrical support systems. Tht equipment, nstrustato le fi ~ ara htabulated.
2. For the fourteen fire zones that the licensee indicates are in full

. / ~pliance wth ftpendix R. but require se %artof wanval orM- _ t161 I I cpwration. he lcensee should describe the safe shutdom nvwlat S

<, cables that would be effected ;by a fire and the specll'lt pr ~ Ctleog that wuld be required to obviate these effects.

, . ~3. The 11 censee should present additional detail 1n regards te rf actions that would be required to prov de alternate shU t _

of the control room and cablt spreading rooms. Is the l`14m . a prepare emrgency procedures to implemnt these operator .ctm_

4. WJill the loss of offslte power affect the capability of su"pl3q dieel generator fuel oil, via the transfer pump$, to both units, S. Performance goals of Section 1I?.L A. Will the reactor trip system be used for shutdown?
b. What is the source of boration and makeup water?
c. Will the pressurizer heaters, or some means of pressure cfttl, b used for shutdown? If So, please describe.
d. Will indications be available for source range inoniteing NW necessary tank levels?
e. What are the ventilation and electrical. distribution system rwired for alternate shutdown.
f. What are the systems required to achieve cold shutdown?
6. Can the units be brought to cold shutdown within 7 hours?

9 W MTIS MGWO j 1

~~~~~~~~~~~~~~BRDOXHAYE ASSOCIED ,W1115 IY 117"7CW

gl1 01-10 f1* lt Tl'*..~i g n ~n o . ~ 9~lI ~i0a. .. mp a a a n7. ' IM-CrTr 1&-e1V I r-'Z, I C7 i CiAs or%-%n-rnAote it, o-r,%r, a, ea, a, Im I O, la ,,

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U ARKANSAS POWER & LIGHT COMPANY.

POST OrrICE BOX 551 LITRE ROCK. ARKANSAS 72203 (5011 371-400 10820262 October 5, 1982

.. ,,f .. _- Z

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0CAN108203 V. CAVA J. CRIMP Director of Nuclear Reactor Regulation r. 1OW ATTN:- Mr. Robert A. Clark, Chief . -! '. .  ! :(.e ..

-'... . -' " --.- a. LA Operating Reactors Branch #3 F. WILO J. LZTYD Division of Licensing ..

U. S. Nuclear Regulatory Commission Washington, 0. C. 20555 J. maw Director of Nuclear Reactor Regulation ATTN: Mr. J. F Stolz, Chief *. Acmmif J. rIy K. bttSAL&

Operating Reactors Branch #4 V

Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. . 20555

SUBJECT:

Arkansas Nuclear One - Units 1 & 2 Docket Nos. 50-313 & 50-368 License Nos. DPR-51 & NPF-6 Request for Additional Information toAppendix R Compliance Submaitttl Gentlemen:

Pursuant to our meeting of August 31, 1982, and your rqust dated September 3, 1982, (CNA098201), we have been requested to furnish additional information concerning safe shutdown capability as ddreuued in our July 1, 1982, Appendix R compliance submittal (AN178"2). We have prepared the following response to each of 7 items for which a response was requested at that meeting.

Item 1:

Provide a summary of the methodology used in reviewing AW-1 & 2 capabilities for hot shutdown and cold shutdown in the event of a fire; and provide some typical examples of the application of your methodology.

Response

The detailed evaluation performed by AP&L to compare AO-1 and AMo-2 to the requirements of Appendix R contained several major tasks which are summarized on pages 2 and 3 of. Section 1 and Appendix E of our July 1.

1982, submittal. In clarification of that information, the following is provided.

MEMMER MtAIOOLC 6CUTR UJTILITIES SYST1EM tt/813 a6ed  !/LZ:6 10-9-Tnr !tb0?,IC?,ICe0VW04en6Ju JaTonN s918lS PeItun :A iu

Mr. Robert A. Clark October 5, 1W?

Mr. John F. Stolz The original Fire Hazards Analysis was used as a basis for the rview.

The evaluation method for this analysis was described in detail in our February 28, 1978, submittal, and was based on the concept of perfemirng and maintaining three shutdown functions, i.e., reactivity c6ntrol primary inventory makeup, and primary heat removal. The ndividui zo"e documentation packages from that analysis consist of a.dscription of the zone, a summary of the potential heat load to the zone rsulting fr.

complete combustion of combustibles (including an assumd 1 x B6 STU of transient combustibles), a list of redundancies identified, a list of safety grade systems which have circuits or components n the zone, a description of the available fire protection, and a list of rateay in the zone. The raceway list includes a list of circuits in the racoway and data for heat load calculations for raceways with exposed cables (trays). Recognizing that some of these documentation peckags mit not contain the latest "as-built" information, we conducted a review of applicable plant design change packages (CP). No modifications re necessary as a result.

With this "initial" data in hand and through use of the latest dravings (P&ID, HVAC, Cable/Raceway, Architectural, etc.) and, where possible, physical observation, each fire zone was reviewed against the Appendix R criteria for fire protection. The basic concept for rview consisted of identifying functional redundancies of safe shutdown comnets located within the zone and determining if the plant could be safely shutdown without those components. If not, then an evaluation was performed to determine if: (1) Appendix R requirements were already met; or (2) sm type modification, alternative' shutdown, exemption request, etc., would be necessary for compliance. If plant-shutdown could be safely accomplished without those components, and since the definition offire zones in the 'original Fire Hazards Analysis' did not require zone boundaries of 3-hour fire rating, adjacent zones as well as zones within 20 feet were considered with regards to their potential effect on redundancy to the zone in question for zone boundaries that had less than a 3-hour fire rating boundary.

The evaluations conducted within the methodology described boye considered associated circuits. This aspect is addressed n detail in ou 1sponse to quest In certain cases, credit for manual operation o equipment w-t if controls (and power for valves) could possibly be damaged by a fire.

Such credit was taken (and noted in Section 2 of our July 1 suhm1ttal) only If:

a. the component to be operated Is not located n the affected fire zone, although the cable may be damaged by fire;
b. sufficient time is available to perform the required ll actions; and
c. personnel are available, beyond the fire brigade and minima operations shift crew limitations,. to perform the manual

. ~acti ons.

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Mr. Robert A. Clark October 5, liw Mr. John F. Stolz These are also discussed in greater detail in our response t question 2.

For redundancies that were still identified as potential safe shutdon concerns following the above review, specific physical separation, barriers, intervening combustibles, suppression systems, tc., wi evaluated and required modifications or alternative eans for accomplishing necessary functions were identified to bring zones into full compliance, or to a level of fire protection safoty.jud to be equivalent to alternatives of Appendix R.

The evaluations described above were performed in accordance with the criteria of Appendix R. including consideration of cable Insulation us combustible, taking no credit for cable coatings to act as a thermal or radiant barrier to protect cables, and diverting primary rliance from administrative controls to preclude fires or damage due to fires.

Attached are documentation packages from one example fire zone from ach unit that demonstrate the application of our methodology. These two zones include one which was found to meet-Appendix R and one which was found to require an exemption. These packages are from the original fire hazards analysis and are only presented for example of t basis of our methodology. As stated earlier, a review was conducted on these paclage to determine all modifications made to these zones subsequent to the Fre Hazard Analysis date. The following paragraph demonstrates the application of or methodology utilizing the example packages attached.

A comparison of the function which requires each red channel circuit with the function which requires each green channel circuit (peos 63.1 through 63.23 of attachment) resulted in the list of rundaniets included in the package (pages 1-59 through I-61 of attachment), nd a subsequent review of the redundancies identified those involving sfe shutdown functions (utilizing drawings and observation). In zne 1WE, the service water sluice gates were Identified as redundant fe shutdro function equipment. It.was also determined that these could be weally operated. As a result of our review of components for spurious actuation problems, the decay heat drop line valves were identified n zone 149-E.

However, it was determined that the control logic for those valves prevented them from being spuriously opened by a fire in this zone.

After completing the review process described above, we concluded this zone met Appendix R requirements. In zone 2040-JJ, the charging pws.

RWT discharge valves, and (for cold shutdown) the shutdown cooling wter heat exchanger service water valves were identified. An exdt1on request was developed for the charging pumps (sunmary of and basis for exemption provided in section E on page 46 of 52 of our July 1 submittal), an alternate source of borated water was identified that Wes available if the RWT valves were lost, and the shutdown cooling ter heat exchanger service water valves were determined to be manually operable for cold shutdown. The results of this analysis are presont*4 I 4 of our July 1 submittal.

Item 2:

For the 14 fire zones that you indicate are in full comliance with Appendix R, but require some sort of manual or non-routine Peratio./

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  • . Mr. Robert A. Clark October 5, 16 hn z describe the safe shutdown equipment and cables that would ffected by a fire and the specific operator actions that would be rired to obviate these effects. In your discussion of this issue discws the times for required action that the operator has before the plant would get nto an unrecoverable situation.

Response

Zones 149E, 67U, 68P and 128E Cables for all the Service Water Sluice Gates are in each of these zones.

If hot shorts somehow selectively closed both gates which permit the pump suction bays to be supplied with lake water and left all 3 of the gates closed which permit the pump suction bays to be supplied with mergency cooling pond water, then one gate would have to be manually opened to maintain suction supply for a service water pump.

With loss of offsite-power, the limiting function of service water in relation to promptness is emergency diesel generator cooling. As noted in Appendix A (A-2.1.f) of our July 1, 1982, submittal, the diesel s not required for at least 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, i.e., until primary system makeup is required.

Zone 170Z The Atmospheric bump Valves and Atmospheric Dump Block Yalves are in this zone. They are required only for cold shutdown. To chieve cold shutdown, one of each in the same loop may have to be manually opened.

Cold shutdown actions can be delayed without limit.

Zone.38Y A cable for CV-1404 (Decay heat drop line from the Reactor Coolant System) is in this zone. To reach cold shutdown that valve uy have to be manually opened. Cold shutdown actions can be delayed without limit.

Zones 79U and 112I Cables for the "C" Makeup pump lube oil pump and the "B'" Makup cooler service water inlet valve are in each of these zones. It A Makeup pumps should be out of service (as permitted for unlimited time periods by the technical specifications) and a fire caused hot short causes the "" Makeup cooler service wateT7nlet valve to close, the "C" Makeup pump can be used for inventory makeup and/or heat removal by overriding the pump lube oil start interlock with a manual Emergency Safeguards nitiation or the "" Makeup pump can be used by manually opening the pump cooler service water inlet valve. Even so, We consider the probability of simultaneous occurrence of this Technical Specification condition and a fire in the same zone extremely small.

Cables for valves CV-1050, CV-1404 and CV-1428 are in tech of the zones and Zone 79U has a cable for CV-1401 and Zone 112I has a cable for CV-1410. Valves CV-1050, CV-1410 and CV-1404 are in the Decay Heat drop line from the Reactor Coolant System and CV-1401 and CV-1428 are in the

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Mr. Robert A. Clark tabor 5, 1W Mr.J Decay Heat cooler discharge line back to the Reactor Coelant Systm. To achieve cold shutdown CV-1050, CV-1404, CV-1401 and CV-142 ay hv to be manually opened for a fire in Zone 79U and CV-1050, CY-1410, CV-1404 and CV-1428 may have to be manually opened for a fire n one 1121. Cold shutdown actions can be delayed without limit.

The makeup pumps can operate on the order of an hour before coolino water flow to the pump is essential. In addition, the requireet to use the makeup pumps does not exist until at least A1/2 hours after a trip coincident with a loss of offsite power and then required use may be intermittent. If the reactor coolant system is tight (low leakage) the requirement may not exist for many hours. As a result, actions to restore cooling water flow or override pump lube oil start interlocks are not expected to be required at all but would certainly not be rquired for a least 3 or 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

Zones 46Y and 47Y Cables for CV-1050 (Decay heat drop line from the Reactor Coolant System) are in these zones. To reach cold shutdown, that valve may have to be manually opened. Cold shutdown actions can be delayed without limit.

Zones 2084DD and 2111T Cables for the srvice water outlet valves from both Diesel Generator jacket coolers are in each of these zones. A fire in either zone along with a loss of offsite power might cause a need for one of those valves to be manually opened. As noted in Appendix A (A-2.1.f) of our July 1.

1982, submittal, the diesel is not required for at least 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> following a loss of offsite power, i.e., until primary system akeup is required.

Zone 2084DD also has a cable for all but one Emergency F.e tar pm discharge valves and several of the valves themselves are physically in this zone. A fire in this zone might cause a need to use fd and bleed cooling or to manually open 2CV-1039 or to manually open 2CV-1036 and 2CV-1075. None of those three valves are physically located within Zone 2084DB nor would a fire in that zone make them inaccessible. Emergency feedwater is required no earlier than 20 minutes on A-2.

Zone 2097X Cables for the green and swing battery chargers are in this zone. If the red battery charger is out of service (as permitted for nlimited tine periods by the technical specifications) and a fire in this zone disabled the green and swing battery chargers, the black battery charger would need to be connected to the red battery. Even so, we consider the probability of simultaneous occurrence of this Technical Specification condition and a fire in the same zone extremely.small.

The battery banks will carry their loads for a least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> without charging. Therefore, connection of a battery bank to an alternate operable charger would be needed no earlier than within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

/

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Mr. Robert A. Clark October 5, 192 Mr. John F. Stolz Zone 2155A The atmospheric dump valves are both in this zone. To achiev" cold shutdown one may need to be manually opened. Cold shutdown actions can be delayed without limit.

Item 3:

List all the actions required of the operator including the times in which the operator has to bring the plant to hot and cold shutdown by means of the alternate shutdown capability independent of the control room and cable spreading room. List manpower requirem.nts for voreous tasks. Provide a commitment and schedule for mplementing procedures for bringing the plant to hot and cold shutdown.

Response

Actions required of the operator to bring the plant to hot shutdon by means of the alternate shutdown system with a loss of 11 AC power, except those corrective actions that may be necessitated by random hot shorts in the able spreading room or control room in order to permit the listed actions to be accomplished, are listed in sections A.2.le and f of Appendix A of our July 1, 1982, submittal. The listed comonents can be operated from the breaker (preferred) or.(in the case of valves) by local manual valve operator manipulation. The listings nclude t m.ep- r requirements for the various tasks. It should be noted that tise actions are the same as those required for a loss of all AC power without a fire for the first 11/2 hours, with the sole difference being the location at which the necessary process variables are monitored. Stop 1 in the list can be delayed in excess of 10 minutes (much longer for Unit 2) without violating margin to saturation limits. Stop 2 is stated in the submittal as having an acceptable delay time of 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Step 3 timing requirements will depend on how tight the Reactor Coolant Stem is and, to some extent, how long Step 1 was delayed, but will be required until some time beyond the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> acceptable delay period for Stop 2.

Step 4 may be delayed without limit.

To achieve cold shutdown the operator will have to continue Steps 3 nd 4 in a manner that will depressurize and cool the Reactor Coolant Systie to approximately 280*F/250 psig where the decay heat system can be put into operation to bring the unit to-cold shutdown. There is no time limit for this task.

Section A.2.1e of our July 1, 1982, submittal commits to revision to existing procedures to address the occurrence of a fire in the control room. These revisions will be implemented after completion of our proposed alternate shutdown design modifications. The schedule for completion of those modifications is addressed n Section of our July 1, 1982, submittal. The procedure revisions will address both hot and cold shutdown.

Item 4:

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If redundant circults were identified within a zone, the d Otto consequences of their loss was determined relative to t a _

the plant. The conditions assumed were a fire coin b wi _a ofOfW power. No additional accident wUs postulated.

If the consequences of the loss of redundaat circuits lo1 a _

determined to be unacceptable, the potential for loss lad to be d _i.

The potential for loss was deterfined as necessamy bauid on piW m qualitative judgments about the area combustibles. If auk wji a could not clearly be made, fire loadings were calculiod and um to __sts

  • acceptability of the potential for damage due to fire.

Redundant equipment within a zone was evaluated in the a described above for redundant circuits.

5.2.2 CRITERIA USED TO DETERMNE ACCEPTABILITY A. No safety equipment or cables in zone; B. No redundant safety equipment or cables in zone; C. Redundant safety equipment or cables within aom buJo ld combustibles other than transient within zone; D. Redundant safety equipment or cables are wi th_ b w s.p M by sufficieat distance without a combustible brid bme or by uals distance and barriers, e.g., walls, to make the prob y ofs Am affecting both extremely small; E. Redundant safety equipment or cables are withn te xm but w Lud from combustion of combustibles within zone not scIt to d _ MO redundant components; F. Redundant safety equipment or cables are within the zone but mdbo k is acceptable with respect to plant safety mador pm d m- rin sOecific to the equipment i vola GC;. Redundant safety cables are within the zone bui the .qms Ji it affects is outside the zone, is accessible, and canibe muly op d. A reasonable amount of time is available to operate the ipoft.

REV. DATE FIRE HAZA3DS ANALY 6 4110/00 PAGE IS OW 2" tv/60 GBed  ! LP :F; Ln-C-Tnr e~~eri~~~LP.:RIn-C-Tflrn' Lt46F~~~ io-i-nLhI

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B. If circuity involving a piece of equipment was lost due to do p sd fire within the zone, that equipment was dee.d bat " _mmofft function of the cable in question. In some inftS w~U iiU wb I=

between the control room and the breaker and no de - M " s the breaker or to the equipment it controlled, creot ukn r sa operation from the breaker.

C. in certain cases, credit for manual operation ofWu p 1 controls (and power for valves) could possibly be dnd by a i Su&

credit was taken only if:

i. The component to be operated was not locd h tba I d an zone, although the cable might be damaped by f;
2. Sufficient time was available to perform t squa p3 operations; and
3. Sufficient personnel were available beyond thu Am b *W to perform the manual actions.

D. For valves required for cold shutdown only, cre& for _ op rd was taken where the valve was physically located wiSa the - of Am damage.*

E. No credit was taken for manual actions which _e ,#I d such as rewiring, deteininating a lead, etc., U Hodfby Appf f cold shutdown considerations.

F. Fire damaged cab es wee assumed to fail in their wont mods b r condition being assessed.

G. The heat load calculations of the original fire hawd , udit considered larger amounts of combustible inoatid mdiN lat v than actually exist in the plant, were used for the Appomiit mau ds.

H. The cable insulation was considered as combut MA L L Nocreditwastakenforcablecoatingstoactazat uwtlo r r to protect cables.

J. The safe shutdown analysis for Appendix R was doin aain t ia off-site power.

REV. DATE FIRE TUADS MALYM 6 4110100 PAGE 17 0 2" L,3 i 4.1 mi. a AR n i - C - - - - - - - - - -.1..

C... . - - ___ 0 - .. .- - - - _. - --

V 5.5.1 INITIAL CONDITIONS AND ASSUMPTIONS A. The safe shutdown analysis for Appendix R is _m _ blahd off-site power.

B. No failures are considered other than those OM rik Iou caused by the fire or by ponded water due to I h I .

C. Fire danaged cables are assumed to fail in the wo ade br tdo conditions being assessed. For example, if it is lifr a va so open rather than remain shut, it is assumed th asm uui MWb a yas to cause the valve to open.

D. Credit for manual operation of manually optv v ws md b_1 -

be taken if adequate time is available for operation, d do vX or breaker is neither physically located within the poJm d Wm re damage nor inaccessible due to the access route b-a blcad bytbv am/

E. For valves required for cold shutdown only, credit fr 'lof may be taken where the valve is physically looed athe 01kw damage.

F. Manual actions that are considered repairs such rwwird d a lead, etc., may only be included for achiev cod *idmn d w be considered for hot shutdown.

G. Embedded conduits are assumed to have adequeu 5.5.2 ANALYSIS The analysis required prior to future plant modifications tb into oo4=

the general requirements. Methods by which these rq-61na we _dsw d maintained are presented in the following sections.

A. ACHIEVING HOT SHUTDOWN

1. Shut down the reactor. This is accomp ad by dfiomia rods or allowing them to fall in from I _o. taI. w damage cannot prevent this action fom ocurfi%.
2. To maintain the reactor subcritical, fir e a t be permitted to dilute the boron concentration the r r cooet system.

REV. DATE F1RE HAZARD AKALY3U 6 4110/00 PAGE 21 0F295

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