ML20195D502

Exemption from 10CFR50,App R Requirements Re Fire Protection Program

ML20195D502
Person / Time
Site:	Arkansas Nuclear
Issue date:	10/26/1988
From:	Holahan G Office of Nuclear Reactor Regulation
To:	ARKANSAS POWER & LIGHT CO.
Shared Package
ML20195D506	List: ML20195D502 ML20195D509
References
NUDOCS 8811070033
Download: ML20195D502 (13)

Text

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UNITED STATES OF APERICA NUCLEAR REGULATORY CCMPISSION i

In the Patter of ll l

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ARKANSAS POWER & l'GHT C0FPANY h

Docket No. 50 313 l

(ArkansasNuclearOne. Unit 1)

EXEMPTION i

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ArkansasPcwer&LightCcrpany(AP&l,orthelicensee)isthehelderof l

Facility Operating License Nc. CPR-51 which authorizes the operatten of 1

Arkansas Nuclear One. Uni.t 1 (the facility) at a steady state power level not in excess of 756E resawatts therral. This license provides, arong other thints, that the facility is subject to all rules, regulations, and Orders of theNuclearRegulatoryCoraission(theCceeissionorthestaff)nowor hereafter in effect. The facility is a pressurized water reactor (FKR) located at the licensee's site in Pope County. Arkansas.

The 10 CFR 50.48 "Fire Protection.' and Append 1* R to 10 CFR Part 50 l

"Fire Protect:on Program for Nuclear Facilities Operating Prior to January 1 I

1979' set forth certain fire protection features required to satisfy the i

General Design Criterion related to fire protection (Criterion 3. Appendix l

A to 10 CFR Part 50).

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Section !!!.G of Appendix R requires fire protection for equipeent L

important to post-fire shutdown. Such fire protection is achieved by various

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t conbinations of fire barriers, fire suppression systees, fire detectors, and separationofsafetytrains(!!!.G.7)oralternatepost-fireshutdownequipment free of the fire area (!!!.G.3). The objective of this protection is to assure that one train of equipment needed for hot shutdown would be undaraged by fire, j

and that systers needed for cold shutdown could be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> t

(!!!.G.1).

I Section !!!.J of Appendix R requires that erergency lighting units with at 1

least an 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> battery power supply be provided in all areas needed for I

eperation of safe shutdown equiprent and in access and egress routes thereto.

Section !!!.0 of Appendix R requires that facilities have a reactor j

coolant purp oil collection system if the containnent is not inerted during 1

norical operation. This system rust be so designcd engineered, and installed t

j that failure during norral or design basis accident cono:tions will not lead to

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fire, and that there is reasonable assurance that the systet. will withstand the l

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i Safe Shutdown Earthquake. Additionally the syster rust drain to a vented i

closed centainer that can hold the entire reactor coolant purp lute oil syster f

inventory.

r By letters dated August 15, 1984 and August 30. 1985, the licensee provided F

detatis of their fire protection program and requested approval of a nurber of enerptions from the technical requireeents of Sections !!!.G. I.I.J. and !!!.0 i

of Appencia R to 10 CFR Part 50. Supplemental inforvation was provided in AP8L l

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1etters dated October 20.1986. April 22 and June 24, 1987, and April ?!.

IfES. A description of the exemptions requested and a sumery of the Comission's evaluation follow.

L Exerotion Requested I

The licensee requested an eserption from Section !41.G.F.b due to a lack of 20 feet of separation free of intervening corbustible u terials between redundant shutdewn related systers in the diesel generator reor. exhaust fan I

outlets area (Fire Area B. Zenes 1-E and 2.E).

The staff's principle concern was that because of the absence of at least 20 feet of separation between the exhaust fan outlets, a pathway exists which could allew fire to spread and darage the redundant systes4. Also, the lack of fixed suppressien systers and fire detectors throughout this fire area could j

4 pervit a fire to spread and result in the loss of safe shutdown capability, i

Povever, because of the light corbustible loading in these fire renes and the j

absence of intervening corbustibles tetween the redundant safe shutdewn i

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systers. it is not expected that a fire of significant duration or regnitude

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will occur. Additionally, with the licensee's comitment to install 3 tcur rated fire doors tetween redundant trains of equipment coepleted, the j

t possibility of a single fire in one of these fire zones damaging redundant j

equipment is very un10ely, despite the horizontal separation distance of less than 20 feet between

%rA it trains. The staff finds that there is I

i reasonable assurance R t a iire in these fire zones will not result in the loss of safe shutdown capability. On this basis the staff concludes that the

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licensee's alternathe fire protection configuration provides an equivalent lesel cf fire safety to that achieved by coepliance with Section !!!.G.P.b.

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4 The special circumstances of 10 CFR 50.12 apply in that application of the regulation in the particular circumstances is not necessary to achieve the underlying purpose of the rule.

In this case the low fire loading, the absence of intervening combustibles, and the installation of the 3-hour rated fire decrs between redundant trains, minimize the possibility of a fire in one train spreading and causing damage to the redundant train equipment. Thus the underlying purpose of the rule would be satisfied without requiring the 20 foot minimum separati distance free of intervening combustible material between the diesel generator room exhaust fan outlets.

5?.'fP. tion, Requested The licensee requested an exemption from Section III.G.2.b due to a lack of 20 feet of separation free of intervening corbustible materials between redundant shutdown-related systems, the borated water storage tank (BWST) outlet valves in the radwaste processing area (Fire Area C. Zone 20-Y).

The staff's principle concern was that a fire of significant naenitude l

cocid damage these valves and prevent safe shutdown conditions from being achieved and raintained. However, the combustible loading in this area is low.

Should a fire occar the existing fire detection system would cound an alarv *n the control room. Soon thereafter the fire brigade would arrive and put out the fire using manual fire fighting equipment. Until the fire is controlled the 1-hour barrier installed around the cables associated with one of the BWST outlet valves would provide sufficient passive protection to assure one shutdown i

train would be free of fire damage. Also due to the low fire loading and the nature cf the valve construction, should the valve electrical circuits become daraged, local ranual valve operaticn would still be pessible to align the proper 1

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, shutdewn flowpath in sufficient time. On this basis the staff concludes that the licensee's alternate fire protection configuration provides an equivalent level of fire safety to that achieved by compliance. with Section III.G.2.b.

The special circumstances of 10 CFR 50.12 apply in that application of the regulation in the particular circumstances is not necessary to achieve the underlying purpose of the rule.

In_this case the low fire loading, the fire brigade response to the fire detection system control room alarm, and the I-hour rated barrier on the cables for one of the two valves provides reasonable assurance that the redundant valve wculd be adequately protected. Additionally, local manual operation of the valves would be possible cespite fire damage to electrical circuits. Thus the underlying purpose of the rule would be satisfied without requiring equiprent separation.

Exempti 3n,R,e,quys,ted The licensee requested an eienption from Section III.G.2.b due to a lack of 20 feet of separation free of intervaning corbustible raterials between redundant shutdcwn-related systems in the emergency feedwater (EFW) purp room (Fire Area C, Zon2 26-Y).

The staff's principle concern was that a fire of significant magnitude could damage redundant EFW trains and prevent safe shutdown from being achieved and maintained. However, the lack of 20 feet of separation between redundant divisions is not significant from a fire safety standpoint for the following reasons. The corbustible loading is low in the EFW pump room. Any fire that 4

occurred would be detected in its femative stages by the existing fire detection system before a significant room temperature rise occurred. This would sound an alam in the control room. Soon thereafter the fire brigade f

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would arrive and put the fire out using the existing ranual fire fighting equipment. Pending arrival of the fire brigade, should rapid fire propagation occur the existing and proposed cable fire barriers, the missile barrier between the two EFW purps, and the proposed automatic sprinkler system would provide reasonable assurance that one division of EFW-related systers would retain free of damage. On this basis the staff concludes that the licensee's proposed alternative fire protection configuration provides an equivalent level of fire safety to that achieved by compliance with Section Ill.G.2.b.

This exemption is granted in part based on the licensee's connitment to complete the following rodifications, by the end of the eighth refueling outage to provide additional protection for the turbine driven EFW pump:

installation of 1-hcur rated fire wrapping on the cables associated with autcratic operation and an automatic sprinkler syster.

The special circ;tstances of 10 CFR 50.12 1pply in that application of the regulation in the particular circumstances is not necessary to achieve the underlying purpose of the rulo.

In this case, the low fire loading, the automatic fire detection system corbined with the tirely response of the fire brigade, e.nd the preposed installation cf autceatic fire suppression ar.d re wrapping coeunitted to by the licensee, all providre assurance that the radundant safe shutdown equipment will be adequately protected. Thus, the underlying purpose of the rule would be satisfied without requiring the minimum of 20 feet of separation between redundant equiprent.

E gmp g n Requested The licensee requested an exemption from Section III.G.P.c due to a lack f

of an automatic fire suppression system to protect redundant shutdcwn-related

systems separated by a 1-hour fire barrier and protected by a fire detection system in the pipe area (Fire Area C Zone 34-Y).

The staff's principle concern was that the lack of an automatic fire suppression system would permit a fire in the area to spread and result in the loss of safe shutdown capability. However due to the light fire loading in the area and the 1-hour rated fire wrapping on the B-train makeup /high pressure injection pump power cables, there is reasonable assurance that a fire in this area would not result in the loss of redundant trains of makeup pumps. Also, the existing fire detection system would sense the presence of a fire and sound an alam in the control room. Soon thereafter the fire brigade would arrive and put the fire out manually with the existing fire fighting equipment. On this basis the staff concludes that the licensee's alternative fire protection configuration provides an equivalent level of protection to that achieved by cor'pliance with Section III.G.P.c.

The special circumstances of 10 CFR 50.12 apply in that application of the regulation in the particular circur'tances is not necessary to achieve the underlying purpose of the rule.

In this case the low fire loading, the existing fire detection system coebined with the timely rtsponse of the fire brigade, and the 1-hour rated barrier around the power cables for the B-train makeup purp, all provide assurance that the redundant safe shutdown equipment will be adequately protected. Thus the underlying purpose of the rule would be satisfied without requiring autoratic fire suppression in this area.

Erenotion Requested The licensee requested an exemption from Section !!!.J due to a lack of 8-hour battery powered emergency lighting units en elevation 317 feet and

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portions of the access paths to the steam pipe area on elevation 404 feet, the intake structure, and diesel fuel storage vaults, all of which are areas required to be manned for safe shutdown.

The staff's principle concern was that a lack of adequate emergency lighting could hinder or prevent licensee personnel from perfonning tasks necessary to achieve safe shutdown. The need for operators to access the safe shutdown equiprent on elevation 317 feet occurs after the 8-hour battery powered errergency lighting time frarre expires. By then normal lighting is expected to be restored.

For the remaining areas, the access paths were determined to be adequately lighted by the yard lighting which is backed up by the security diesel generator. This generator is not vulnerable to fire loss under the postulated fire scenarios. Additionally, the yard lighting is maintained as part of the licensee's plant security plari requirements. On this basis the licensee's alternate lighting arrangement in the subject areas achieves an equivalent level of sa hty to that required by compliance witti Section !!I.J.

Tho special circurnstances of 10 CFR 50.12 apply in that application of the regulation in tht particular circumstances is not necessary to a:hieve the underlying purpose of the rule.

In this case the existing lighting is adequate. Thus the underlying purpose of the rule would be satisfied without requiring installation of emergency lighting.

Exemption Requested The licensee requested an exeeption from Section !!!.G.?.a due to a lack of a complete 3-hour fire-rated barrier between redundant level transmitters forthesafetygradecondensatestoragetank(QCST)(YardArea).

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-l The staff's principle concern was that a-fire could result in damage to redundant corponents or cables associated with the QCST level indication.

However, there are no significant unmitigated in-situ fire hazards which would represent a risk to these components.

In addition, the introduction of significant quantities of transient combustibles is precluded by the difficult access to the location of the components. Should a fire occur it would t

probably be of limited ragnitude, and the resulting sroke and hot gases would l

tend to be dissipated in the open air, away from the subject components. The physical configuration of the areas where the GCST level indication components o

are located will provide sufficient protection to assure that at least one safe shutdown train will remain free of fire dar. age until the fire brigade arrives I

to extinguish the fire utilizing existing fire fighting equipment. On this basis the staff concludes that the licensee's alternate fire protection configuration provic'es an equivalent level of fire safety to that achieved by compliance with Section !!!.G.2.a.

The special circumstances of 10 CFR 50.12 apply in tilat applicatten of the regulation in the particular cire,uestances is not necessary to achieve the underlying purpose of the rule.

In this case the absence of significant in-situ fire hazards, and the physical location and arrangement of the equipment provide assurance that the redundant level indication equipment would be adequately protected until the fire was brought under control by the fire brigade. Thus the underlying purpose of the rule would be satisfied without requiring a 3-hour fire-rated barrier between De redundant QCST level transmitters.

. Exes tion Requested The licensee requested an exerption from Section I!!.0 due to a lack of a reactor coolant pump oil collection system that is designed to withstand a safe shutdown earthquake (SSE) and sized to hold the oil from all reactor coolant pumps.

The licensee stated in a letter dated August 15, 1984 that the reactor coolant pump lube oil systems are qualified to remain functional during and after an SSE. Therefore, the following guidance of Generic Letter 86-10 "Irplementation of Fire Protection Requirements," applies:

Where the RCP lube oil system is capable of withstanding the safe shutdown earthquake (SSE), the analysis should assume that only randem oil leaks from the joints could occur during the lifetime of the plant. The oil collection system, therefore, should be designed to safely channel the quantity of oil from one pump to a vented closed container. Ur. der this set of circumstances, the oil collection system would act have to be seismically designed.

T6e existing oil collection system is designed to safely channel the quantity of oil frot one purp to a vented closed container, and so confoms with the above staff guidance. On this basis the staff concludes that the 11cersee's alternate design of the oil collection system provides an equivalent level af fire safety to that achieved by compliance with Section III.O.

The specla' circumstances of 10 CFR 50.12 apply in that application of the regulation in the particular circumstances is not necessary to achieve the un.derlying purpose of the rule.

In this case the design of the reactor coolant purp 1 bricating systems and the oil collection systems meets certain criteria previously detennined by the staff to be acceptable for assuring z

adequate fire safety. Thus the underlying purpose of the rule would be satis-l fied without requiring the oil collection system to be seismically qualified and capable of holding the oil contained ;n all of the reactor coolant pu'tps.

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Exemption Requested The licensee requested an exemption from Section III.G.P.b due to a lack of an automatic fire suppression system to protect redundant emergency feedwater (EFW) pump cables (Fire Area C. Zones 20-Y and 34-Y).

The staff's principle concern was that a fire of significant magnitude would occur and damage the reduridant EFW pump cables. However, the fire leading in the area is low, consistirg primarily of cables in trays. A fire in this area would be characterized initially by low heat release and limited flame propagation. The existing smoke detection system would be expected to actuate and sound an alann in the control room. The fire brigade would prcrptly respond and extinguish the fire with the existing manual fire, fighting equipment. Pending their' arrival the spatial separations which is at least 26 feet between the cables of the redundant trains, provides reasonable assurance that at least one train would remain free of fire dange. On this basis the staff concludes that the licensee's existing fire protectioc. provides an equivalent level of fire safety to that achieved by cc:rpliance with Section III.G.2.b.

The special circumstances of 10 CFR 60.12 apply in that acplication of the regulation in the particular circumstances is not necessary to achieve the underlying purpose of the rule.

In this case the low fire loading, the spatial separation between redundant cable trains, and the automatic smoke detection system combined with the timely response of the fire brigade to the control room alarm, all provide assurance that the redundant safe shutdown i

equiprent would be adequately protected until the fire is brought under control. Thus the underlying purpose of the rule would be satisfied without requiring an automatic fire suppression system.

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Accordingly, the Comission has detennined that pursuant to 10 CFR 50.12, this Exemption it, authorized by law, will not present an undue risk to the public health and safety, and is consistent with the comen defense and security. The Connission has further determined that special circumstances, as setforthin10CFR50.12(a)(2)(ii),arepresentjustifyingtheexemption, nerely that the application of the regulation in the particular circumstances is not necessary to achieve the underlying purpose of the rule.

Specifics are discussed in each exemption request, but in general the underlying purpose of the rule is tc accomplish safe shutdown in the event of a single fire and raintain the plant in a safe condition. This is accomplished by assuring that sufficient undamaged equipment is available to support safe shutdown, assuming a fire within the area of concern.

In the areas for which an exemption is being requested, passive as well as active fire protection featuras assure that any single fire will not result in the loss of safe shutdown capability. These features include separation distance, fire barriers, water spray systers to preclude propagation, and ra9ual actions. The fire protection features, in conjunction with low combustibla loadings and in sore cases physical location and configurations, provide a high degree of assurance that a single fire will not result in loss of post-fire shutdown capability. At this time, the licensee has not completed two of the modifications upon which one of these exemptions is based. However, the licensee has in place acceptable corpensatory measures and is comitted to the completion of the modifications by the end of the eighth refueling cutage.

Accordingly, the Comission hereby grants the exerptions from the requirerents of 10 CFR Part 50. Appendix R as described in Section 111 above.

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Pursuant to 10 CFR 51.32, the Connission has determined that the granting of this Exemptien will have no significant impact on the environment (53 FR 27091).

The Safety Evaluation concurrently issued and related to this action and the above referenced submittals by the licensee are available for public inspection at the Comission's Public document Room, 2120 L Street, N.W.,

Washington, D. C., and at the local public document room located at the Terlinson Library, Arkansas Technical University, Russellville, Arkansas 77F,01.

This Exemption is effective upon issuance.

FOR THE NUCLEAR REGULATORY COPNISSION

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V Gary M. Holahan, Acting Director Division of Reactor Projects - !!!, IV, V and Special Projects Office of Nuclear Reactor Regulation Dated at Rockville, Paryland this 26th day of October, 1988 4

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