ML18031A696
| ML18031A696 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 08/07/1986 |
| From: | Clark R Office of Nuclear Reactor Regulation |
| To: | White S TENNESSEE VALLEY AUTHORITY |
| References | |
| NUDOCS 8608190438 | |
| Download: ML18031A696 (12) | |
Text
August 7, 1986 Docket No. 50-259/260/296 Mr. S. A. White Manager of Nuclear Power Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, Tennessee 37401
Dear Mr. White:
By letter dated January 31, 1986, you submitted a revised fire protection and safe shutdown analysis for the Browns Ferry Nuclear Plant to demonstrate plant compliance with 10 CFR 50.48 and 10 CFR 50 Appendix R.
During our review of your submittal, there have been frequent discussions and several meetings with your staff - including two visits to the site - to clarify aspects of your fire protection program.
We have completed our review and are preparing a
draft safety evaluation.
As we discussed with your staff in the meetings at the site on June 23-24,
- 1986, we plan to issue a final safety evaluation after we have an opportunity to review the implementing procedures which you are preparing.
during our review, your staff was very cooperative and responded expeditiously to our requests for clarifying information.
AS we advised your
- staff, we would identify the information which needed to be formally submitted.
The purpose of this letter is to identify the responses which we are requesting you to submit.
Your submittal requested several technical exemptions to 10 CFR 50 'Appendix R, most of which appears to be reasonable and acceptable.
Our review of these exemptions was based on a revised revision of Section 10 of your submittal provided to us on April 25, 1986.
Your revision to Section 10 must be formally submitted.
ON December 12, 1985, revisions to 10 CFR 50.12(a)
- were, published in the Federal Register (50 FR 50764) setting forth cr'iteria for granting of exemptions from the requirements of 10 CFR Part"50.
Your submittal of January 31, 1986 did not address the information required by this final rule.
Fore us to process your request, you must. provide the information required by the revised 10 CFR 50. 12(a), including a discussion of which of the "special circumstances" in Section
- 50. 12(a)(2)(i) thru (vi) are present.
The other responses which we are requesting you to;,'submit are identified in the enclosed -request for additional information.'608i90438 860807 PDR ADOCK 05000259 F
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f The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.
Sincerely,
Enclosure:
As stated cc/w enclosure:
See next page (ggnat elgnH @
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"I Mr. S.
A. l!hite Tennessee Val 1 ey Authority
'Browns Ferry Nuclear Plant Units 1, 2, and 3
CC:
H. S. Sanger, Jr., Esouire General Counsel Tennessee Yalley Authority 400 Commerce Avenue E 11B 330 Knoxville, Tennessee 37902 Mr. Ron Rogers Tennessee Valley Authority 5N 130B Lookout Place Chattanooga, Tennessee 37402-2801
- Chairman, Limestone County Commission Post Office Box 188
- Athens, Alabama 35611 Ira L. Meyers, M.D.
State Health Officer State Department of Public f!ealth State Office Building Montgomery, Alabama 36130 Mr. K. l!. Mhitt E3A8 400 Hest Summit Hill Drive Tennessee Valley Authority Knoxville, Tennessee 37902 Reqional Administrator, Reqion II U. S. Nuclear Regulatory Commission 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 Mr. Steven Roessler U. S. Nuclear Regulatory Commission Reactor Training Center Osborne Office Center, Suite 200 Chattanooga, Tennessee 37411 H. C. Bibb Site Director, BFNP Tennessee Valley Authority Post Office Box 2000
- Decatur, Alabama 35602 Resident Inspector U. S. Nuclear Regulatory Commission Route 2, Box 311
- Athens, Alabama 3561')
Mr. Donald L. 'l!illiams, Jr.
Tennessee Valley Authority 400 Hest Summit Hill Drive, I!10B85 Knoxvi'lie, Tennessee 37902 Robert L. Lewis, Manager, RFNP Tennessee Valley Authority Post Office Box 2000
- Decatur, Alabama 35602
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RE VEST FOR ADDITIONAL INFORMATION RAI REVIEW OF BROWNS FERRY FIRE PROTECTION SUBMITTAL BROWNS FERRY NUCLEAR PLANT UNITS 1
2 AND 3 DOCKET NOS. 50-259,
- 260, and 296 The following information is needed to perform an evaluation of certain sections of the Licensee's submittal titled, " 10 CFR Appendix R Submittal, Fire Protection and Safe Shutdown Systems Analyses Report for Browns. Ferry Plant," prepared by General Electric and dated January 1986.
1.
When the Commission approved 550.48 and Appendix R to 10 CFR 50, they specified that Section III.G, III.J, and III.O should be applicable to all nuclear power plants operating prior to January 1, 1979, regardless of pri,or fire protection modifications made by the licensee or of prior approval by the staff of those modifications.
The third sentence of the first paragraph of the Executive Summary of the January, 1986 submittal
- reads, "The analyses were performed to demonstrate plant compliance with 10 CFR 50.48 and 10 CFR 50 Appendix R."
Also, in the fourth paragraph of the Executive
- Summary, "The fire protection modifications ensure that each fire area on fire zone has adequate separation from adjacent fire areas or zones.
New fire doors, dampers, barriers, sprinklers, water curtains, water sprays, and detectors will be installed for fire protection enhancement."
However, other statements imply that TVA=has not re-evaluated all fire protection modifications approved by the staff in the 1976 fire recovery plan.
These specific statements in the January, 1986 submittal illustrate our concern.
A.
Section 4.4.3.7, page 4-34, second paragraph.
"The detectors were approved in accordance with the fire recovery plan (Reference 15 and 16)."
B.
Section 7.2. 1, page 7-20.
"Some of these fire areas were previously approved by the NRC (References 15 and 16).
Some of these fire areas may require upgrading to bring the fire barriers to the required rating."
C.
Section 8. 1, page 8-2.
"Where NFPA code requirements will affect both the new and existing portions e.g., air supervision for preaction
- systems, that particular code requirement will not be considered applicable to the proposed modifications."
2.
3.
4, Please state that all fire area and fire zones containing redundant safe shutdown cabling, components or equipment have been evaluated for compliance with Section III.G of Appendix R to 10 CFR 50, either when currently proposed modifications are completed, or when the staff approves the current TVA requests for exemption.
- Further, please state that all fire protection modifications made by TVA and approved by the staff as part of the 1976 recovery plan have been re-evaluated and found to comply with the requirements of Appendix R to 10 CFR 50. If TVA has not made such a determination, this will remain as an open item in the staff's evaluation and Safety Analysis Report.
Page 2-3.
Verify that fire area/fire zone boundaries are covered by Technical Specifications.
Page 3-6.
Verify that a "postulated fire" is assumed to occur
~an here in any area containing electrical circuitry or components necessary for safe
- shutdown, whether or not the area contains permanent combustible materials.
In lieu of this, verify that damaging effects of a fire are assumed to spread uniformly throughout the area.
Page 3-6.
Verify that the concept of "zone of influence" is applicable only in areas fully covered by automatic sprinkler protection.
5.
Page 3-8.
The phrase under Manual
~0 aration, "ifaccessibility and staffing levels permit such act>one, is not clear.
(A) Does this imply possible manual actions within the area of fire occurrences?
If yes, demonstrate that such assumptions are valid and describe timing constraints that will govern manual actions in areas of fire occurrance.
6.
7.
(B) Since staffing levels fluctuate among the 21 shifts each week, verify that assumptions made concerning manual actions are based upon minimum staffing levels.
Page 4-35.
Provide an evaluation of reactor building areas having partial sprinkler and fire detection systems for compliance with Sections III.G.2.b and III.G.2.c of Appendix R.
Page 7-35.
Elaborate on how the requirements of III.G.2 across the fire zone boundaries has been assured.
8.
Table 7-9, Pages 7-36 through 7-50.
State under the "Separation" column. walls, doors,
~dam ers, or seals as appropriate, for each heading wWwere tlia't informat>on is m>ssing to provide information concerning the nature of the opening.
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9.
Table 7-9, Pages 7-36 through 7-50, and Page 8-19, paragraph a.
Explain how 1-hour duct wrap and 1-hour rated seals, provide protection equivalent to required 3-hour fire rated barriers and seals.
Table 7-10, Pages 7-51 through 7-54.
Provide design details on hatch sprinklers, hatch and stair enclosures, water curtains, sprinklers in ducts and fire dampers (generic).
Page 8-2.
A statement is made that some NFPA code criteria may not be applicable or met.
Please identify all significant NFPA code deviations.
12.
13.
14.
15.
16.
17.
18.
19.
Page 8-3.
Identify the "style" of fire detection device circuits to be implemented at Browns Ferry.
Page 8-3.
The use of nonsupervised fire detection circuits is not acceptable; therefore, provide a description of alternative design.
Elaborate on how the issue of smoke stratification has been addressed in the design of the fire detection systems (generic).
Page 8-4.
Explain or give examples of where water spray shields are or would be required qnd installed.
Page 8-6, Paragraph 6.
Please give maximum straight line spacing of automatic sprinklers in addition to statement that spacing will not exceed 130 sq. ft. per sprinkler.
Page 8-6, Paragraph d.
Provide the rationale or basis for the selection of high temperature sprinkler heads in the RHR pump rooms, especially since these high temperature sprinklers are located under open metal grating.
Page 8-9, Paragraph a.
Define the term "substantial noncombustible material" as used to descr ibe construction of draft stops.
Page 8-19, Paragraph a.
The statement that, "pipe, conduit, and cable tray penetrations will be sealed with seals rated at one hour or better or with a roved desi 'n - (emphasis added),"
implies that unapprove esign may e used.
Please provide design details for any penetration seals that do not conform to staff fire protection guidelines or designs that have been tested and found acceptable by the staff.
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20.
Page 8-19, Paragraph b.
Where automatic sprinkler protection is provided within a duct, what provisions have been made for removing excess water to prevent either structural failure of the duct, or making a travel path for water to unwanted locations.-
- Also, please provide results of the evaluation mentioned on Page 8-26.
21.
Page 8-20 and Table 8-2.
Do modifications B and C include rated fire doors and frames'?
If not, please provide the means used to demonstrate equivalent protection is provided.
Also, are all fire doors, including any non-rated
- doors, covered by Technical Specifications governing operability, approved hold open devices, kept closed, manual or electrical supervision, posted fire watch if door left open, etc.Y 22.
Page 8-39.
Describe the design of the cable wraps selected for fire protection.
23.
A significant part of the overall fire protection program at Browns Ferry Nuclear Plant consists of systems for fire detection and/or fire suppression.
These systems are designed for either automatic or manual operation, are often interconnected, and include the following:
Yard fire main loop including the motor and engine driven fire pumps isolation valves, yard hydrants, and connections to automatic and/or manual water (sprinkler and deluge) systems and manual standpipe and hose installations.
Automatic and/or manual water sprinkler and deluge systems.
Manual standpipe and hose systems.
Automatic gaseous suppression (CO~ or Halon) systems.
Automatic fire detection systems.
(Some detection systems give alarm only of fire condition while others also initiate automatic suppression systems - deluge, water flow for pre-action sprinklers, CO, and Halon gaseous suppression.)
Please describe procedures followed to assure that all systems A.
Pass an acceptance test based upon applicable National Fire Protection Association (NFPA) standards and the manufacturer's specifications following initial installation or major repairs or modifications to the system.
B.
Pass periodic calibration and operational tests as required by applicable National Fire Protection Association standards, the manufacturer's recommendations, or good engineering practice.
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