ML20206U432

Forwards Notice of Withdrawal of Licensee 961106 Request for Approval of Deviation from Approved Fire Protection Program to Extent Program Incorporated Technical Requirements of Section III.G.2 of App R to 10CFR50

ML20206U432
Person / Time
Site:	River Bend
Issue date:	05/18/1999
From:	Robert Fretz NRC (Affiliation Not Assigned)
To:	Edington R ENTERGY OPERATIONS, INC.
Shared Package
ML20206U437	List: ML20206U432 ML20206U438
References
TAC-M97241, NUDOCS 9905250210
Download: ML20206U432 (5)

Text

,

9 CC120 y t UNITED STATES s# j 2

NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20066 4 001

\ . . . . . ,o! May 18, 1999 Mr. Randall K. Edington Vice President - Operations Entergy Operations, Inc.

River Bend Station P. O. Box 220 St. Francisville, LA 70775

SUBJECT:

RIVER BEND STATION, UNIT 1 - WITHDRAWAL OF APPLICATION FOR LICENSE AMENDMENT TO REVISE FIRE HAZARDS ANALYSIS REPORT AND SAFETY ANALYSIS REPORT (TAC NO. M97241)

Dear Mr. Edington:

By letter dated November 6,1996, Entergy Operations, Inc. (EOl), requested the approval of a deviation from its approved fire protection program to the extent the program incorporated the technical requirements of Section Ill.G.2 of Appendix R to Part 50 of Title 10 of the Code of Federal Reaulations (10 CFR).

Attachment 4," Fire Protection Program Requirements," to the River Bend Station (RBS) Facility Operat'.ng License NPF-47 (FOL) states, in part, that:

1. EOI shallimplement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility through Amendment 22 and as approved in the SER dated May 1984 and Supplement 3 dated August 1985 subject to provisions 2 and 3 below.

2. EOl may make no change to the approved fire protection program which would significantly decrease the level of fire protection in the plant without prior approval of the Commission. To make such a change EOl must submit an 1 application for license amendment pursuant to 10 CFR 50.90.  !

l

3. EOl may make changes to features of the approved fire protection program i which do not significantly decrease the level of fire protection without prior .

Ccmmission approval provided (a) such changes do not othenvise involve a l change in a license condition or technical specification or result in an unreviewed safety question (see 10 CFR 50.59), and (b) such changes do not result in failure to complete the fire protection program approved by the Commission prior to license issuance. EOl shall maintain, in an auditable form, a current record of all y

s such changes, including an analysis of the effects of the change on the fire protection program, and shall make such records available to NRC inspectors upon request. All changes to the approved program shall be reported to the Director of the Office of Nuclear Reactor Regulation, along with the FSAR ,

revisions required by 10 CFR 50.71(e).

dN E M EFE @

9905250210 990518 0 PDR ADOCK 0500 P

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R. K. Edington May 18, 1999 The proposed deviation request sought NRC approval for the use of a partial area automatic suppression system in lieu of a full area automatic suppression system in RBS Fire Area C-16.

Fire Area C-16 contains Division ll safe shutdown cables that were once protected by what had been credited as a 3-hour fire barrier. In response to Thermo-Lag fire barrier issues and related ampacity concems, the 3-hour barrier was replaced with a rated 1-hour barrier in combination with aren-wide smoke detection and a limited automatic suppression system. The original automatic suppression system design was confined to sprinkler heads above and below the Division ll cable tray. The November 6,1996, letter stated that the request to deviate from the requirements of 10 CFR Part 50, Appendix R, Section Ill.G.2.c, was submitted pursuant to 10 CFR 50.90, ostensibly in accordance with Requirement 2 of Attachment 4 to the RBS FOL.

A summary of the proposed amendment request and accompanying basis for a proposed no significant hazards consideration determination was published in the Federal Reaister on December 4,1996 (61 FR 64385).

By letter dated July 31,1997, EOl provided supplementary information following the NRC's request for additional information (RAl) dated June 16,1997. In its July 31,1997, letter, EOl revised its original design to include sprinkler protection above and below the Division I cable trays in addition to the Division 11 trays. EOl later provided additional information requested by I the NRC staff in a letter dated April 13,1998. In the April 1998 letter, the deviation request was also referred to as a " request for exemption" to the requirements of 10 CFR Part 50, Appendix R, Section Ill.G.2. Furthermore, the letter stated that the sprinkler system installation l for the Division I cable trays would be deferred, pending NRC approval of the proposed  !

limited-area suppression system design, and that a roving fire watch would be instituted in the interim.

EOl subsequently withdrew its request in, a letter dated December 17,1998, following its determination that the proposed change could be performed without NRC prior approval pursuant to Requirement 3 of Attachment 4 to the RBS FOL. The letter requesting withdrawal stated "[bjecause the change does not involve a significant decrease in the level of fire protection, the license condition allows RBS to implement the change." ,

in acknowledging EOl's withdrawal of its request for approval of a deviation from its approved fire protection program to the extent the program incorporated the technical requirements of 10 CFR Part 50, Appendix R, Section Ill.G.2, the NRC staff agrees that it is acceptable for EOl to make changes to its approved fire protection program without prior NRC approval in accordance with the RBS FOL. Generic Letter (GL) 86-10 further reinforces that a licensee may alter specific features of its approved program provided (a) such changes do not otherwise involve a change to a License Condition or Technical Specifications or result in an unreviewed safety question (in accordance with the requirements of 10 CFR 50.59), and (b) such changes do not result in failure to complete the fire protection program as approved by the NRC.

Changing the means of ensuring that one of the redundant trains is free of fire damage from a 3-hour rated fire barrier (Appendix R, Section Ill.G.2.a) to a 1-hour rated fire barrier with fire detection and a partial automatic fire suppression system in the fire area (affording less coverage than required under Appendix R, Section Ill.G.2.c) may be acceptable providea the actual change would afford an adequate level of safety.

Recognizing that varying plant configurations existed, the NRC provided three acceptable, and different, means to ensure safe shutdown capability in Appendix R, Section Ill.G.2. Three acceptable options were specified in the regulation as opposed to requiring licensees to design

R. K. Edington May 18, 1999 protective features for a specific design basis fire hazard. The bases for these technical requirements are provided in the Final Rule publication for Fire Protection Programs for Operating Nuclear Power Plants (Fedam! Register, Volume 45; No. 225; November 19,1980; page 76606). It states, in pri, that "because it is not possible to predict the specific conditions under which fires may occur and propagate, the design basis protective features are specified rather than the design bzsis fire. Three different means for protecting the safe shutdown I capability outside conNnment are acceptable..." (i.e., Appendix R, Section Ill.G.2.a/b/c.)

In the course of reviewing EOl's request prior to its withdrawal, the staff noted deficiencies in the proposed automatic fire suppression system design from the specifications of National Fire Protection Association (NFPA) 13, " Standard for the Installation of Sprinkler Systems." The deficicncies included:

• The classification above the cable trays as a " Light Hazard" as defined by NFPA 13, i Section 1-4.7 (See also GL 86-10, Question 3.4.1); l

• The use of small orifice sprinkler heads (

Reference:

NFPA 13, Section 2-2.2.1);

• The use of pendent style spdnklers, without retum bends, on a non-potable water supplied system (

Reference:

NFPA 13, Section 4-5.17);

• The location of the sprinkler heads with respect to NFPA 13 requirements (

Reference:

NFPA 13, Omtion 4-4);

• The use of a nonconservative Hazen-Williams "C" factor in the hydraulic calculations

(

Reference:

NFPA 13, Section 6-4.4.5); and

• The determination of the physical area for partial protection (

Reference:

NFPA 13, i Section1-4.2 and GL 86-10). j The staff has discussed these design deficiencics with your engineering staff, and many of these same deficiencies were later substantiated by your consultant, Duke Engineering Services (DES).

On the basis of the staff's current understanding of the proposed changes, including the changes made following the DES recommendations, the staff's primary concern of the extent and adequacy of the partial-area automatic fire suppression system remains unresolved.

GL 86-10, Enclosure 1 " Interpretations of Appendix R,* Question 5," Automatic Detection and Supprenshn," and Question 3.4.2 recognize that a less than full area suppression system in a fire area may be adequate to meet the underlying purpose of the technical requirements of Appendix R for some specific plant configurations. Question 3.4.2 also references NFPA 13, Section 4.1.2.

However, during several telephone conferences with EOi, the staff expressed the concern that

" spot" protection, and not partial-area protection was being provided. A review of the NFPA l Code in effect at the time GL 86-10 was prepared, the 1983 Edition of NFPA 13, yields the following: "When partial sprinkler installations are installed, the requirements of this standard snail be used insofar as they are applicable. The authority having jurisdiction shall be consulted in each case." The Code (NFPA 13) offers further explanation in Appendix A, Section A-4.1.2, as stated: "When buildings or portions of buildings are combustible construction or contain combustible material, standard fire barriers should be provided to separate the areas which are sprinkler protected from adjoining unsprinklered areas." RBS does not use any standard fire

barriers to separate these areas. The version of NFPA 13 at the time of the RBS design i change (the 1994 Edition) contains the identical Code requirement in Section 1-6.2 titled, l

I

R. K. Edington May 18, 1999

" Limited Area Systems." The NFPA " Automatic Sprinkler System Handbook," Sixth Edition, provides insights to this Code requirement in Section 1-6. The handbook states that "NFPA 13 has always required sprinklers throughout the premises. The few omission rules contained in this standard are relatively recent. Sprinkler systems are not designed to halt a fire front advancing from an unsprinklered area to a sprinklered area." The handbook further discusses that the use of limited area systems are intended for special r.pplications such as to provide additional time for occupant evacuation, i.e., life safety. The NFPA handbook concludes this section by stating that "such a system would not be expected to sufficiently control the fire, and therefore property damage would most likely be severe."

Therefore, on the basis of the information reviewed, the staff considers the partial-nrea sprinkler system design for Fire Area C-16 a significant decrease 'n the level of fire protection in the plant from levels established by the approved RBS fire protectioa program, and would not meet the underlying purpose of 10 CFR Part 50, Appendix R, Section !!! G.2, to provide reasonable assurance that the pbr.1 can achieve and maintain safe shutdown conditions in the event of a fire.

Accordingly, the NRC concludes that EOl cannot implemsnt the proposed change, as submitted, without prior approval since the change would result in a decrease in the level of fire protection in the area. Nevertheless, the NRC is permitting your withdrawal of the November 6, 1996, request for approval of a deviation from your approved fire protection program to the extent it incorporated the technical requirements of Section Ill.G.2 of Appendix R to 10 CFR Part 50, as supplemented by letters dated July 31,1997, and April 13,1998. In order to resolve the interim conditions implemented in Fire Area C-16, EOl may subsequently make changes to the features of the approved fire protection program without prior NRC approval, provided the requirements of Attachment 4 to the RBS FOL are met.

If the information regarding your withdrawal request is not correct, please notify the NRC of your intended actions within 10 days of receipt of this letter. The Commission has filed the enclosed Notice of Withdrawal of Application for Amendment to Facility Operating License with the Office of the Federal Register for publication.

Sincerely, ORIGINAL SIGNED BY Robert J. Fretz, Project Manager, Section 1 Project Directorate IV & Decommissioning Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-458 DISTRIBUTION SRichards ACRS

Enclosure:

Notice of Withdrawal Docket File OGC PUBLIC K.Brockman, RIV cc w/ enc!: See next page PDIV-1 Reading K.S. West DOCUMENT NAME: G:\RIVERBND\WD97241.WPD To receive copy of document. indicate: c = copy w/o enci E = copy w/enct N = No copy

• See Previous Concurrence OFFICE PDIV 1/PM E PDIV-1/LA_ E- SPLB* OGC* PDIV-1/SC_ b NAME RFretz hf[ LBerry KSWest* SHom* RGramm b DATE I/ /# 99 b / h /99 4/29/99 5/10/99 h / N /99 OFFICIAL RECORD COPY

River Bend Station l

cc:

Winston & Strawn Executive Vice President and l 1400 L Street, N.W. Chief Operating Officer l Washington, DC 20005-3502 Entergy Operations, Inc. I P. O. Box 31995 Manager - Licensing Jackson, MS 39286 Entergy Operations, Inc.

River Bend Station General Manager - Plant Operations P. O. Box 220 Entergy Operations, Inc.

St. Francisville, LA 70775 River Bend Station l l

P. O. Box 220 Senior Resident inspector St. Francisville, LA 70775 i P. O. Box 1050 l St. Francisville, LA 70775 Director - Nuclear Safety ,

Entergy Operations, Inc.

President of West Feliciana River Bend Station Police Jury P. O. Box 220 ,

P. O. Box 1921 St. Francisville, LA 70775 l St. Francisville, LA 70775 Vice President - Operations Support l Regional Administrator, Region IV Entergy Operatior.s, Inc.

U.S. Nuclear Regulatory Commission P. O. Box 31995  !

611 Ryan Plaza Drive, Suite 1000 Jackson, MS 39286-1995 l Arlington,TX 76011 ,

Attorney General Ms. H. Anne Plettinger State of Louisiana 3456 Villa Rose Drive P. O. Box 94095 Baton Rouge, LA 70806 Baton Rouge, LA 70804-9095 Administrator Wise, Carter, Child & Caraway Louisiana Radiation Protection Division P. O. Box 651 P. O. Box 82135 Jackson, MS 39205 i Baton Rouge, LA 70884-2135