ML19326C632

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Documents Commitments Re Fire Protection Made in 780524 Meeting W/Nrc.Svc Water Drawing Encl
ML19326C632
Person / Time
Site: Arkansas Nuclear  Entergy icon.png
Issue date: 06/15/1978
From: David Williams
ARKANSAS POWER & LIGHT CO.
To: Reid R, Stolz J
Office of Nuclear Reactor Regulation
References
1-068-3, 1-68-3, NUDOCS 8004240572
Download: ML19326C632 (12)


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4 h06hJl&Y REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

DISTRIBUTION FOR INCOMING MATERIAL -31' 368 i

REC: STOLZ J F ORG: WILLIAMS D H DOCDATE: 06/15/78 I NRC AR PWR & LIGHT DATE RCVD: 06/23/78 l DOCTYPE: LETTER NOTARIZED: NO COPIES RECEIVED 1

SUBJECT:

LTR 3 ENCL 40 1 FURNISHING COMMITMENTS MADE BY APPLICANT DURING MEETING. WITH NRC STAFF ON 05/24/78 RE FIRE PROTECTION ISSUES OF SUBJECT FACILITY.. W/ATT.

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ARKANSAS POWER & LIGHT COMPANY POST OFRCE BOX 551 03DOCKETFIE ,,

UTTLE ROCK. ARKANSAS 72203 (501) 371-4000 f, ,

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Director of Nuclear Reactor Regulation ATTN: Mr. J. F. Stolz, Chief Light Water Reactors Branch #1 Mr. Robert W. Reid, Chief Operating Reactors Branch #4 U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Subject:

Arkansas Power & Light Company Arkansas Nuclear One-Units 1 & 2 Docket No. 50-313 & 50-368 License No. DPR-51 Fire Protection (File: 1050, 2040, 2-1050, 2-2040)

Gentlemen:

The following the Staff, on Mayis24,to 1978.

document comitments made during our meeting, with itemsapplicable.

where and the r umber in parenthasis refers to the previous staff ,

Item 1 -

Power Supplies for Fire Detection and Actuation Circuits Response (ANO-1)

Although we do not agree with the necessity of the requested modifications f all Fire detectors will be powered from an emergenc ,

of power available curing a loss of offsite power).y power source (a source be completed by October 1,1978. This modification will We now consider this item resolved.

Item 2 -

Smoke detectors in the ANO-1 Emergency Feedwater Pump Room

_ Response (ANO-1)

Although smoke detector we do not agree with the necessity of the requested modification, EFW pump room.(s), which alann in the control room will be provided in the [A y consider this item resolved,This modification wil' be completed by October We 1,1978.

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, t Mr. J. F. Stolz, Chief Mr. Robert W. Reid, Chief June 15, 1978 1-068-3 2-068-8 Item 3 (PF.21)

Smoke detectors which alarm.in the Control Room should be located in all safety-related areas containing combustibles.

Response (ANO-l&2)

This item will be the subject of subsequent correspondence based on the June 9,1978, meeting.

Item 4a Provide barriers betwaen redundant conduits in Fire Zone 149-E.

Response (ANO-1)

We do not believe this is a justifiable position as there are no com-bustibles in this zone. However, in order to expedite licensing, we will provide a barrier between the two redundant conduits. This modification will be completed by the end of the next refueling outage. We consider this item resolved.

Item 4b - Deleted Item 4c - Fire Barriers in Zone 98-J Response (ANO-1) i We are still evaluating the best engineering modification for this zone.

We will either install a deluge system with directional spray actuated by heat and smoke detection and provide cable coating where redundancies are in proximity or coat all trays and provide smoke detection with alarms in the Control Room, and a wet pipe sprinkler system. We understand eit5er of these modifications is acceptable to the staff. The modifica-tion will be completed by the end of the next refueling outage. We consider this item resolved.

Item 4d - Fire Barriers in Zone 2091-BB Response (ANO-2)_

A marinite board will be added to cover tray EB155 and those portions of EB154 where redundancies are in proximity. This modification will be complete by June 19, 1978. We consider this item resolved.

Item 4e - Fire Barriers in Zone 2111-T l l

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t Mr J. F. Stolz, Chief Mr. Robert W. Reid, Chief June 15, 1978 1-068-3 2-068-8

Response

The two (2) redundant circuits of concern are in EBil92 and EB236 with some black trays as combustible bridges. A marinite barrier will be installed between the two circuits and the black trays where in proximity or the black trays will be coated where in proximity to the redundant circuits.

This modification will be completed by June 19, 1978. We consider this item resolved.

Item 4f - Fire Barriers in Zone 2109-U Response (ANO-2)

Same as response to Item 4c Item 40 - Fire Barriers in Zone 2084-DD Response (ANO-2)

Since there are no combustibles in this zone and the circuits in question are in conduit, we do not believe the requested modification is justifi-abl e. However, in an effort to expedite licensing, we will coat one of the conduits where they are in proximity. Due to the physical location of the conduits, it is impossible to provide a barrier. This modification will be complete by June 19, 1978. We consider this item resolved.

Item Sa - Manual Hose Reels in Zone 2223KK Response (ANO-2)

We understand the stuff has taken a further look at the separation of circuitry in this zone and determined that a hose reel is not required in this zone. We consider this item resolved.

Item Sb - Manual Hose Reels in Zone 2055JJ Response (ANO-2)

We have further analyzed this zone and have detennined that loss of all the safety related ' circuitry in this zone combined with a single failure out-side the zone will not jeopardize our ability to safely shutdown the plant.

We understand that the staff will accept this zone without the addition of a manual hose. Therefore, no hose reels will be added. We consider this item resolved.

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Mr. J. F. Stolz, Chief Mr. Robert W. Reid, Chief June 15, 1978 1-068-3 2-068-8 Item Sc - Manual Hose Reel in Zone 2084DD Response (ANO-2)

We will replace the 75' hose on HR2-28 with a 100' hose. This is adequate hose to reach zone 2084DD. This modification will be completed by October 1,1978. We consider this item resolved.

Item 5d - Manual Hose Reels on El. 317' ANO-1 & ANO-2 Response (ANO-1 & ANO-2)

Our Fire Hazards Analysis has shown conclusively that a fire on this elevation would not jeopardize our ability to safely shutdown the plant as none of the equipment on these elevations is necessary for safe shutdown. We therefore do not believe the requested modi-fication is justifiable as a modification to improve the margin of safety to the health and safety of the public. However, as an effort to expedite licensing, we will provide manual hose capability for these elevations. The modification will be complete by the end of the next refueling outage of each unit. We consider this item resolved.

Item 6 - Protection Against loss of Service Water - ANO-1 Response (ANO-1)

As stated in our response to verbal question 2 transmitted to you April 26, 1978, there are circuits associated with two pumps routed in common conduits and trays. However, these circuits are control circuits. The circuits in question are the red control to the red pump and the red control of the swing pump. Destruction of one of the conduits / tray could only disable one pump as green control would be available to the swing pump. As illustrated on the attached drawings, there are no situations where power cables from two pumps are routed in the same conduit / tray and the destruction of one of those conduits / trays would only possibly disable one pump. We believe this is adequate justification for deletion of the position and based on the staff response to this, we consider this item resolved.

Item 7a (1.0j) - Fire Protection Quality Assurance Program Response (ANO-1 & 2)

The guidelines of Attachment No. 6 to your " Nuclear Plant Fire Protection Function Responsibilities, Administrative Controls and Quality Assurance" dated June 20, 1977, will be met by application of the appropriate sections of our QA Topical with the following exceptions:

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. l Mr. J. F. Stolz, Chief Mr. Robert W. Reid, Chief June 15, 197.8 1-068-3 2-068-8 Item 3.0 - Control of Purchased Material, Equipment and Services Vendor qualification criteria listed in APL-TOP-1 A will not be followed for qualification of vendor supplied parts, components, or services.

Upon implementaion of the Fire Protection Plan, all fire protection equipment procured, will be UL or FM listed, where applicable. This will be accomplished by requiring such on the purchase order.

Item 4.0 - Inspections Response (AN0-1 & ANO-2)

This item will be complied with by applying applicable portions of the QA Topical, Fire Protection Plan, and Technical Specifications.

Item 5.0 - Test and Test Control This item will be complied with by applying applicable portions of the QA Topical, Fire Protection Plan, and Technical Specifications.

Item 10.0 - Audits ,

Response (ANO-1 & ANO-2)

This section will be complied with by performing audits in accordance with applicable sections of the QA Topical except section d which will be complied with by application of our Technical Specifications.

Item 7e (2.0n) - Review of Work Request by the Fire Chief Response (ANO-l & AN0-2)

All job orders will be reviewed for fire protection impact by the Plant Fire Chief or the Shift Supervisor. We understand this is acceptable to the Staff and consider this item resolved. This commitment will be reflected in an amendment to the Fire Protection Plan.

Item 8a - Testing of Cable Penetration Fire Stops Response (ANO-1)

We will perform fire tests or supply adequate information of tests on similar fire stops to justify the adequacy of the cable penetration fire stops.

Details and a schedule for completion of testing (if required), will be submitted by October 1,1978. We understand that the staff considers this connitment sufficient to resolve this issue.

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Mr. J. F. Stolz, Chief Mr. Robert W. Reid, Chief June 15, 1978 1-068-3 2-068-8 Item 8b - Safety Circuits in Non-safety Related Raceways Response (ANO-1)

As discussed in our meeting with the staff on May 24, 1978, we must per- .

form a considerable amount of analysis to detennine if tnis situation exists at our facility. We will provide you with a schedule for com-pletion of the analysis by July 15, 1978.

Item 8c - Portable Air Handling Equipment Response (ANO-1 & ANO-2)

We will provide three (3) 5,000 CFM (minimum) smoke exhaust units available for each unit. Flexible duct will also be provided to aid in the removal of smoke. This equipment will be provided by December 1,1978. Ne consider this item resolved.

Item 8d - Supervision of valves of the Fire Water System

. Response (ANO-1 & ANO-2)

We understand that, at least for now, our technical specifications are adequate to resolve this issue.

Item 8e - Automatic Operation of Sprinkler Systems Response (ANO-1)

We understand the staff is concerned with the manual sprinkler systems in zone 149E and both ANO-1 Diesel Generator Rooms. We will modify these systems to automatic actuation by the end of the next refueling outage.

We consider this~ item ree;lved.

Item 8f - Water Spray Protection for Motor Control Centers

Response

Our Fire Hazards Analysis has shown that the loss of'either or both of the two MCC's (2851 and 2861) would not affect the ability to safely shutdown the plant. It is our opinion that providing the requested modification will not significantly increase the margin of safety to the health and safety of the public. However, as an effort to expedite licensing, we will provide a shield to protect the two MCC's from water spray. This modi-fication will be made by September 1, 1978. We consider this item resolved.

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Mr. J. F. Stolz, Chief Mr. Robert W. Reid, Chief June 15, 1978 1-068-3 2-068-8 Item 89 - Details of RCP C1 Collection System Response' (ANO-1 & ANO-2j_

We will provide the requested sketches and/or photogaprhs of the RCP oil collection system by September 1,1978, for ANO-2 and following the next extended outage, but no later than after the next refueling outage for ANO-1.

Item 8h - Smoke Detectors in Areas of Combustibles Response (ANO-1 & ANO-2)

This item will be the subject of subsequent correspondence based on the June 9, 1978, meeting.

Item 81 - Smoke Detectors for Actuation of Halon System Response (ANO-1)

We will modify the Halon System in the false ceiling and floor of the ANO-1 control room to be activated by smoke detectors. This modification will be completed by the end of the next refueling outage. We consider this item resolved.

Item 8j - Replace non-UL/FM Listed Detertors Respons.: (AND-1)

We are identifying the location of all non-UL/FM listed detectors and evaluating their necessity. Those identified that are detennined necessary by your requirements and/or our convitments will be replaced (if possible) by UL/FM listed equipment. This analysis and modification (if necessary) will be completed by September 1, 1978. We consider this commitment adequate to resolve this issue.

I' tem 8k (PF.14) - Hose Reel in Containment Response (ANO-1 & ANO-2)

Manual hose capability will be provided in the Reactor Building (ANO-1) and I Containment Building (ANO-2) by the end of the next respective refueling outage. We consider this item resolved.

Item 9.la - Control Room Cabinet with Redundant Safe Shutdown Equipment

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Mr. J. F. Stolz, Chief .

Mr. Robert W. Reid, Chief 1-068-3 Juna 15, 1978 2-068-8

_ Response (ANO-1 & ANO-2)

The only 2C33. Control Room cabinet with redundant safe snutdown circuitry is cabling except for a common open area ,at the We topwillof the cabin provide detection consistent with our comitment in our April 24, 1978, letter. We consider this item resolved.

Item 9.lb Combined With 9.la - Resolved floor and ceiling. Item 9.lc - Redundant safe shutdown circuitry in ANO-1 C Rerponse ( AN0-1)

There is no redundant safe shutdown circuitry in the false ceiling. The false floor area contains all control circuits. Since all safety circuits are in conduit, we propose to provide a cable coating on all open trays.

We believe the number of barriers necessary to achieve complete separation of conduits and trays would render the Halon System useless. Coating each tray along with the modification to llalon System detection should provide this item.more than adequate protection and should be sufficient to resolve Item 9.2a - ANO-1 Cable Spreading Room Response (ANO-1) i We will either provide a deluge system similar to item 4c cable coating for each open cable tray.

completed item resolved.

by the end of the next refueling outage.This modification will be We consider this Item 9.2b and 9.2c - ANO-2 Cable Spreading Room .

_ Response 2

The total ceiling area 0.23 provide of this zone is 2484 ft . Sprinklers located at the gpm/ft2 sprinklers provide 0.21 gpm/ftof2 floor areaofand or a '.otal 0.44the inteqdiate level gpm/ft This system uns isdesigned andtoinstalled of floor area.

1977 and therefore not designed that code.before the issuance of NFPA 35, to evaluate this system with respect to the new code.It is not practical put s.ignificantly less water into the zone than our pre

Mr. J. F. Stolz, Chief Mr. Robert W. Reid, Chief -9 '

June 15, 1978 1-068-3 2-068-8 Although all trays do not receive direct spray, the trays are no more than 18 to 20% full and extremely clean. Water should pour through upper trays and impinge on lower trays very effectively.

.We trust this infonnation is sufficient to resolve your concern in this area.

In addition, we will provide a flame retardant barrier and/or cable coating where redundant safe shutdown circuitry are in proximity.

This modification will be provided by the end of the first refueling outage. We consider this item resolved.

Item 9.3 - Barriert in ANO-2 Switchgear Room Response (ANO-2)

We will provide a fire retardant barrier or coating where two chan::els of circuitry are. in proximity. This modification will be completed by the end of the first refueling outage. We consider this item resolved.

Item 9.4a - Emergency Lights in the Control Room Response (ANO-1 & ANO-2 Fixed emergency lights will be provided in the Control Rooms by December 1,1978. We consider this item resolved.

Item 9.4b - Portable Hand Held Lights Response (ANO-1 & ANO-2)

Ten (10) hand held sealed beam lanterns will be provided for fire fighting use by July 1,1978. We consider this item resolved.

The implementation schedules presented here are realistic as of this date. However, for inodifications to be performed during the next ANO-1 i refueling outage, ali engineering and review must be completed by 1 November 1, 1978. Shoeld NRC or required insurance review delay completion of design change package and impcat this date, the implementation schedule could also be impacted. Also, should we have procurement problems, ,

these implementation dates could be impacted. We anticipate you will be considerate of these problems should they occur. Should the Staff 1

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l Mr. J. F. Stolz, Chief Mr. Robert W. Reid, Chief June 15, 1978 1-068-3 2-068-8 Response (ANO-1 & ANO-2) (Cont')

. review our Fire Hazard Analysis to its fullest extent and fully consider the information we believe it contains, the need for many of the above modifications will be negated. We reserve the right to reconsider these commitments with the staff should that review occur.

Very truly yours, 1/ '

Daniel H. Williams Manager, l.icensing DHW/JTE/ew 4

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