ML20128Q878

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Forwards Fire Hazards Analysis Reevaluation, Containing Technical Exemption Requests from Provisions of 10CFR50, App R,Per IE Info Notice 84-09 & Generic Ltr 83-33. Justification for Continued Operation Encl
ML20128Q878
Person / Time
Site: Farley Southern Nuclear icon.png
Issue date: 05/31/1985
From: Mcdonald R
ALABAMA POWER CO.
To: Varga S
Office of Nuclear Reactor Regulation
Shared Package
ML20128Q882 List:
References
GL-83-33, IEIN-84-09, IEIN-84-9, TAC-57854, TAC-57855, TAC-57856, TAC-60032, NUDOCS 8506040332
Download: ML20128Q878 (3)


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Malling Address l A1:bama Power Company 600 North 18th Street

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A Post Office Bov 2641 Birmingham, Aiabama 33291 Telephone 205 783-6090 R. P. Mcdonald i

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Docket No.'50-348 Director, Nuclear Reactor Regulation U. S. Nuclear Regulatory Consnission Washington, D.C.

20555 Attention: Mr. S. A. Varga t

Joseph M. Farley Nuclear Plant - Unit i 10CFR50.48 and 10CFR50, Appendix R Fire Protection Exemption Requests Gentlemen:

As discussed in Alabama Power Company's letter dated March 13, 1985 which submitted the exemption requests for all Unit 2 and shared fire areas, a second review of the Farley Nuclear Plant fire areas in Unit 1 was conducted. This review was conducted to determine the level of compliance with the requirements of 10CFR50.48 and 10CFR50, Appendix R

-in light of the interpretations to Appendix R set forth in IE Notice 84-09 and Generic Letter 83-33. As a result of this review, the enclosed document J. M. Farley Nuclear Plant - Unit 1,10CFR50 Appendix "R" Fire Hazards Analysis Reevaluation: May 1985 containing the technical exemption requests from the provisions of 10CFR50 Appendix R is submitted, pursuant to 10CFR50.12(a), for NRC approval. Appendix R compliance reports for each unit, including the criteria used for the review, will be prepared and are scheduled to be available at the plant site by the end of 1985.

Except as described below, all modifications identified in the In enclosed technical exemption requests have been implemented.

technical exemption requests 1-035 and 1-037,' Alabama Power Company proposes to install disconnect switches outside the electrical penetration room for the charging pump suction and discharge valves.

Consequently, a schedular exemption is also requested, pursuant to 10CFR50.12, from the requirements of 10CFR50.48(c)(3). The requested schedular exemption is to allow installation of the modifications described in exemption requests 1-035 and 1-037 to be deferred until the first outage of sufficient duration subsequent to design and procurement completion, but no later than the Unit l' seventh refueling outage which Qii19 i

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8506040332 850531 pa ^=n oS3 8J 9

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Mr. S. A.. Varga May 31, l'985

' U. S.' Nuclea'r Regu'latory Commission Page 2 is currently scheduled for. the fourt!h quarter of 1986. The need for

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this modification was not-identified until February 27, 1985. Design and material needed for this modification could not be obtained in time to; allow -installation of these modifications during the Unit 1 sixth

. refueling outage (the estimated lead time on the Class I-E disconnects is 12-16 weeks).. Compensatory actions which will be taken until the modifications areL completed are described in the exemption requests.

Also included in the enclosed document is Revision 1. to exemption request 2-018. submitted in the March 13,'1985 letter. This revision provides the correct justification for ensuring the service water inlet valve to CCW heat-exchanger 2B is maintained open in the event the CCW pump 2C and CCW heat-exchanger 2C are out of service.

It should be noted that Alabama Power Company has developed and implemented a detailed shutdown / repair procedure for a cable spreading room fire in Unit 1.

This scenario is considered to have the most severe impact on plant safe shutdown and recovery. This procedure conforms to the guidance issued in Generic Letter 83-33.

Similarly, detailed procedures for all other fire areas of the plant will be developed based upon the detailed unit compliance report and implemented

. prior to the end of the Unit i seventh refueling outage currently scheduled to connence during the fourth quarter of 1986. These procedures will include any operator action identified in the attached exemption requests. Consequently, a schedular exemption.is also requested,.

10CFR50.48(pursuant to 10CFR50.12, from the requirements ofc)(1) for this procedur described above. Justification for. continued operation untti these procedures are developed and approved is provided in Attachment 1.

In accordance with 10CFR170.21, enclosed is the application fee of

$150.00.

If you have any questions, please advise.

Yours very ly, )

R. P. Mcdonald RPM /DHJ:bdv-037 cc: Mr. L. B. Long Regional Administrator Mr. E. A. Reeves Mr. W. H. Bradford Mr. G. F. Trowbridge L

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' Justification for Continued Operation The 'following justification _for continued operation is' provided

-until detaileC procedures for fire areas other than the cable spreading L

' room fire _ are developed.

(A procedure for the cable spreading room has n

= been _ issued).EThese detailed procedures will be based upon.the detailed

unit ^ compliance report and will be. implemented prior to the end of the~

Unit.1 seventh refueling outage currently scheduled to connence during the1 fourth quarter of 1986.

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Operators will be made aware that the enclosed-document contains information that can assist them in responding to a fire in an area other than the cable spreading room.

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Additional operator actions / repairs that are _necessary to

. achieve cold shutdown are longer term items which would allow time for. operator determination of the problem and the j

appropriate. solution.

To assist in this determination of. the problem, the operators.

have available:

a) Existing Emergency Response Procedures, while not written to specifically address a fire in an area, could be used by the operator in the presence of potential fire damage to a single train,

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b) existing emergency assistance organizations comprised 1-of scheduled on-call personnel with established contacts within the design organization, c) the design organization with responsibility for the Appendix R analysis has available information which can be used to determine the appropriate action.

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