ML19343C851

Submits Fire Protection Upgrade Response to 10CFR50.48 & 10CFR50 App R Requirements.Info Re Implementation Schedule, Plant Areas Inaccessible While Unit Is Operating & Design Description for Alternate Shutdown Encl

ML19343C851
Person / Time
Site:	Farley
Issue date:	03/19/1981
From:	Clayton F ALABAMA POWER CO.
To:	Schwencer A, Varga S Office of Nuclear Reactor Regulation
References
NUDOCS 8103250429
Download: ML19343C851 (7)

Text

Alabama Power Company a -

600 North 18th street roit Offica Box 2641 Birmingham. Alabama 35291 Teleonone 205 2501000 F. L. CLWTON, JR.

m senior vae President Alabama Power tM soumern eec:nc swe<~

March 19,1981 Docket No. 50-348 Docket No. 50-364 3

Director s',2 Nuclear Reactor Regulation $

U. S. Nuclear Regulatory Commission j h" c

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h Washington, D. C. 20555 ,, 4%.

jt "tg n Attention: Mr. S. A. Varga Q' * -

W Mr. A. T. Schwencer **

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Gentlemen: 4/ -

D Farley Nuclear Plant Units 1 and 2, Fire Protection Upgrade Response to 10CFR50.48 and 10CFR50 Appendix R Requirements Alabama Power Company submits this response as required by the refer-enced regulations. In compliance with these regulations, the following information is enclosed:

Implementation Schedule - Attachments 1 and 2 Plant Areas Inaccessible While Unit is Operating -

Attachment 3 Design Description for Alternate Shutdown - Attachment 4 Alabama Power has recently completed extensive modifications and up-grades to its fire protection program as a result of the Fire Protection Program Reevaluation; therefore, only Sections III.G, III.J and III.0 of Appendix R apply to the Farley Plant.

The detail modifications that are planned in order to meet the require-ments of Section III.G.3 of Appendix R are scheduled for submittal to the NRC for review and approval in October 1982 for Unit 1, and in March 1982 for Unit 2. We wish to call your attention to the implementation schedule bases in that this schedule is predicated upon estimated dates for material delivery and currently scheduled outages. The implementation of the neces-sary design changes will be completed no later than the return to power following the fifth refueling outace for Unit 1 and the second refueling outage for Unit 2. While this schedule is beyond the NRC schedule, the R\

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e Director, Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission March 19, 1981 Page Two necessary actions and accompanying schedule outlined in Attachment 2 is the

only schedule that allows the required actions to be taken within the con-straints of planned plant operations. As outlined in Attachment 2, certain actions cannot be performed during the same outage (e.g. designer walkdown and contractor walkdown).

If you have any questions, please advise.

Verytrulyy{,s, F. L. Clayton, Jr.

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V FLCJr/EAW:nac Attachments

, xc: Mr. R. A. Thomas I Mr. G. F. Trowbridge Mr. L. L. . Kintner Mr. W. H. Bradford Mr. E. A. Reeves i .

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4 Attaciment I

t AtillCIPA1ED OUTAGE SCHEDULE FOR FilP FOR APPENDIX R Pt ANNING l .

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OUTAGE UNIT 'STARTUP OUTAGE 4-NO.' DATE (2 weeks) . FIRST SECOND THIRD ' FOURTil FIFTH 1 4-1 2-22 82 to 4-1-82 2-22-83 to 4-1-83 2-22 84 to 4-1-84 4-1-82 to 415-82 2 1-1-81 1-1-83 to 2-8-83 1-1-84 to 2-8-84 4

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t Attachrient 2 Page 1 of 2 PLAN AND SCllEDULE FOR FIRE PROTECTION PROGRAM FOR .

OPERATING POWER PIANTS PART 50.48 AND 10 CFR 50 APPENDIX R CONTRACTOR SalEDUIE DESICN SalEDUIR DESIGN FINAI.

FWP PREPARATION ANALYSIS AND PREPARATION DESIGN 10 CFR 50 UNIT FOR OF CDNTRACTOR FOR AND INSTALIATION .

APPE*4 DIX R NO. WAIKDOWN WAIKDOWN WAIKDOWN SEIE CTION WAIXDOWN '

WAIEDOWN P ROCUREMENT C)MPIITE III C 2 1 5-1-81 6-1-81 8-1-81 9-1-81 10-1-81 11-1-81 12-1-81 5 82 (rand C 1) accessible a reas I only -

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1 11-1-81 4-1-82 * ' 8 82 9 82 12-1-82 4-1-83 8-1-83 4 84 I inaccessible areaa f' 2 4-1-81 6-1-81 10-1-81 11-1-81 1-1-82 4-15-82 6-1-82 2-8-83 2 week t urbine inspection III C 3 1 3 82 4 82 8-1-82 -

10-1-82 4-1-84 **

2 4-1-81 6-1-81 10-1-81 3 82 2-8-84 *

• III 7 Both 00MP12TE

' III O 1 10-1-81 4-1-82 2 10-1-81 2-8-83 D

• Perform at refueling outage or at earlier unanticipated outage of sufficient duration assimiing availability of hardware af ter completion of walkdown gN preparation.

• • Predicated upon MtC review and approval of the detailed design.

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ATTACHMENT 2 Page 2 of 2 Schedule Bases Bases for this schedule are as follows:

_. 1. Walkdown and work functions in inaccessible areas are done only during scheduled outage or unscheduled outages of sufficient duration assuming availability of hardware.

2. Analysis of walkdown information is approximately two to four months dependent upon simultaneous workload of both units.

3. Based upon actual time tables for similar work on Units 1 and 2 to comply with the Fire Protection Program Reevaluation (FPPR):

a. Procurement of fire barrier material is approximately six months.

b. Procurement of smoke detectors approximately six months.

c. Completion of the vendor supplied smoke detector design is approximately nine months,

d. Procurement of alternate shutdown control multiplexing system is approximately 18 months.

e. Installation time for fire barriers is approximately six months.

f. Installation time for sprinklers is approximately six l months.

! g. Minimum time for the selection of the contractors will only be one month.

The schedule shown in Attachment 2' lists the various steps i- h.

for completion. No step can be eliminated or performed simultar.e;usly with a subsequent step, such as engineer and contractor walkdown.

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ATTACHMENT 3 _

INACCESSIBLE AREAS FOR APPENDIX R IMPLEMENTATION Containment Cable Spread Room

-Main Steam Valve Room Battery-Charger Room D. C. Switch Gear Room

. Rod Control Cabinet Room Auxiliary Feedwater Pump Room Charging Pump Room l

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Attachrent :

DESIG?; DESCRIPTIO!i FOR A1.TER? TATE ShUTIG?i FOR FARLEY ?CCI. EAR PLANT In order to reassess the existing design features of the clant for cercliance with the requirerents of Section III.G.2 of Apcendix R to 1GCFR Part 50, additicnal plant walkdcun and engineering analysis will be recuired. The scheduled ccepletion dates for ne walkdewns and analyses are shewn on the attached schedule. Eased on the infer .aticn cbtained fecc the walkdcwns and analyses. a determination of cccpliance er ncn-ccc:liance to Section III.G.2 of Appendix R will be : ade. For fire areas whica do not cccoly with the requirerents of Section III.G.2 cf Acpendix R, the felicwing action will be taken:

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a) The cen-ccco:iance will be corrected by rercuting raceway cr adding one-hour fire barriers and fire su;cressicn and detecticn systens to cocply with Section III.G.2 of Atpendix R, or b) Alternative shutdcun cacacility will te provided in cercliance with Section III.G.3 of Appendix R, (engineering investigations include at this tire the multiplexing of indicaticn and centrol signals to and free the Alternate Shutdcwn Fanel), or c) An exemption will be requested with sufficient justification.

Consideration in the evaluaticn will include the asscciated circuits, wnich are those circuits:

a) considered asscciated by being electrically ccnnected to the shutdcwn train, b) censidered associated by proximity t0 the shuthcwn train.

Circuit breakers, fuses, and current limiters used in these asscciated circuits are censidered to be s:.fficient to reet the protection criteria.

An alternate hot shutdown pane. is provided as backup for the centrol recc and cable spreading roce. . Inadvertent water suppressicn is detricental to plant safety and operation; The control roce is- centinucusly.cccupied which assures early fire detectico and superession. Cedicated suppressica in -

these . areas .is icpractical, as stated in the Farley Fire Protection Progran Reevaluation.

The scheduled coraletion dates for perferning t."e detailed engineeries i required for acdifications, and the extended coefietien dates for ir4:lecenting

- the 'recuired redifications are shown en Attach =ent 2 g . . _ _ _