ML20207F497

Ack Receipt of Informing NRC of Actions to Correct Deviations Noted in Insp Repts 50-313/87-14 & 50-368/87-14.Response Does Not Justify Lack of Surveillances of Certain Fire Barriers

ML20207F497
Person / Time
Site:	Arkansas Nuclear
Issue date:	08/10/1988
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Campbell G ARKANSAS POWER & LIGHT CO.
References
TAC-68238, NUDOCS 8808180296
Download: ML20207F497 (4)

See also: IR 05000313/1987014

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In Reply. Refer To: AllG l 01988

Docket:: 50-313/87-14

50-368/87-14

Arkansas Power & Light Company

ATTN: Mr. Gene Campbell

Vice President, Nuclear

Operations

P.O. Box 551

Little Rock, Arkansas 72203

Thank you for your letter of March 28, 1988, in response to our letters

and the attached Notice of Deviation dated September 30, 1987, and Jar;ary 27,

1988. As a result of our review and an evaluation by NRR, we find that your

rc:,ponses to the Notice of Deviation do not justify the lack of survrlPance

]f the certain fire barriers.

A copy of the NRR evaluation is enclosed. Please provide a revisei response to

the deviation within 30 days of the date of this letter whi_ch addresses the

conclusions of the NRR evaluation.

Sincerely.

OrJginal SJgna gy

L J. Callan

L. J. Callan, Director.

Division of Reactor Projects

Enclosure:

As stated

cc:

Arkansas Nuclear One

ATTN: J. M. Levine, Director

Site Nuclear Operations

P.O. Box 608

Russellville, Arkansas 72891

Arkansas Radiation Control Program Director

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ENCLOSURE

EVALUATION OF LICENSEE'S RESPONSE TO NOTICE OF DEVIATION

ARKANSAS NUCLEAR ONE, UNITS 1 AND 2

(TAC NO. 68238)

1.0 INTRODUCTION

As a result of an Appendix R to 10 CFR 50 compliance assessment inspection at

Arkansas Nuclear One, Units 1 and 2, (Inspection Report 50-313/87-14 and

50-368/87-14) a Notice of Deviation was issued. This deviation identified that

Arkansas Power & Light Co. (the licensee) committed to establish and maintain

a fire protection program under the guidelines of Appendix A to Branch Technical

Position APCSB 9.5-1. Under thls program, the plant was divided into distinct

fire areas by fire-rated walls and floor / ceiling assemblies which were to be

surveilled under the provisions of the plant Technical Specifications. Contrary

to the above, certain barriers which are necessary to satisfy the above referenced

guidelines were not being surveilled as with other Technical Specification

barriers.

2.0 DISCUSSION

The licensee responded to the Notice of Deviation in letters to the staff

dated November 30, 1987 and March 28, 1988. AP&L agreed in the November 30,

1987 letter that certain fire barriers, previously designated as being required

to satisfy the above-referenced staff guidelines, are not presently being

surveilled per the Technical Specifications. However, the licensee's position

is that these barriers are no longer required to be surveilled per the Technical

Specificctions. This position is based on the premise that the requirements of

Appendix R to 10 CFR 50, related to the delineation of fire areas, supersedes

the curresponding guidelines in Appendix A to the Branch Technical Position.

, In conjunction with the licensee's efforts to evaluate the plant to the require-

ments of Appendix R, fire areas were redefined. This was accomplished in

accordance with the guidelines issued in Generic Letter 83-33. The staff

evaluated and approved the new fire area boundaries in conjunction with the

review of the post-fire safe shutdown methodology. The licensee has now

concluded that those fire barriers that do not coincide with the Appendix R

fire areas need not be encompassed by the plant Technical Specifications.

3.0 EVALUATION

The licensing basis for ANO 1/2, as with all plants licensed prior to January 1,

1979, include the guidelines of Appendix A to BTP APC5B 9.5-1 and the requirements

of Sections III.G, III.J., and III.0 of Appendix R to 10 CFR 50.

The guidelines in Appendix A to the BTP comprehensively address the aspects of

an acceptable fire protection program. Section D.1 stipulates that plants

should be designed to both "isolate safety related systems from unacceptable

fir? hazards" and to assure that safe plant shutdown could be achieved and

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maintained following a fire. Specific construction requirements for fire

barriers for select plant areas are delineated in Section F. The requirements

of Section III.G of Appendix R, however, are limited to establishing an accep-

table level of protection to assure that one division of safe shutdown systems

is free of fire damage. They do not address those fire barriers required to

isolate significant fire hazards. The Appendix R barriers are, therefore, a

subset of the total number of reoubed fire barriers. An example of this

concept is the floor / ceiling assembly which separates the control room from the

cable spreading room. From an Appendix R perspective this barrier could be

eliminated because the alternate shutdown capability would assure that post fire

safe shutdown could be achieved. However, because of the significant fire

loading associated with cable insulation, the barrier is necessary to isolate

the cable hazard from the control room. Similar arguments can be made for

barriers which isolate turbine oil fire ha:ards in the Turbine Building.

The need for surveillir.g all fire barriers which satisfy NRC fire protection

criteria is reflected in the Bases of the ANO 1/2 Technical Specifications for

fire barriers. The bases states:

"The functional integrity of the penetration fire barriers ensures

that fires will be confined or adequately retarded for spreading to

adjacent portions of the facility. This design feature minimizes the

possibility of a single fire rapidly involving several areas of the

facility prior to detection and extinguishment. The penetration fire

bar,iers are a passive element in the facility fire protection program

and are subject to periodic inspections."

4.0 CONCLUSION

Based on the above evaluation the staff concludes that all fire barriers which

are necessary to satisfy the guidelines contained in Appendix A to BTP APCSB

9.5-1 and the requirements of Section III.G. of Appendix R to 10 CFR 50 should

be encompassed by Section 3/4.7.11 Penetration Fire Barriers of the Arkansas

Nuclear One Technical Specification.

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