ML20210C220

Exemption from App R of 10CFR50,Section Iii.G Re 27 Specific Fire Areas

ML20210C220
Person / Time
Site:	Farley
Issue date:	09/10/1986
From:	Novak T Office of Nuclear Reactor Regulation
To:	ALABAMA POWER CO.
Shared Package
ML20210C226	List: ML20210C220 ML20210C233
References
TAC-57854, TAC-57855, TAC-57856, TAC-60032, NUDOCS 8609180289
Download: ML20210C220 (5)

Text

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.I 7590-01 UNITED STATES NUCLEAR REGULATORY COMMISSION ~

In the Matter

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Docket No. 50-348

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ALARAMA.F0WER COMPANY I

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(Joseph M.- Farley Nuclear Plant i

Units No.-1)

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EXEMPTION I.

The Alabama Power Company (the licensee) is the holder of Facility Operating License No. NPF-2 which authorized operation of the Joseph M. Farley

. Nuclear Power Plant Unit No. 1.

This licerse provides, among other things, that the licensee is subject to all rules, regulations and Orders of the Commission now or hereafter in effect.

The facility comprises two pressurized water reactors at the licensee's site located near the City of Dothar, Alabama.

II.

On November 19, 1980, the Commission published a revised Section 10 CFR 50.48.

' and a new Appendix R to 10 CFR 50 regarding the fire protection features of i

nuclear power plants (48 FP 76602). The revised Section 50.48 and Appendix R became effective on February 17, 1981. Section 50.48(c) established the schedules for satisfying the provisions of Appendix R.

Section III of Appendix R contains fifteen subsections, lettered A through 0, each of which l

specifies requirements for a particular aspect of the fire protection features at a nuclear powe plant. Only one of the fifteen subsections, III.G, j

is the subject of this exemption request.

8609180289 860910 PDR ADOCK 05000348 F

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\\ j Section III.G.2 of Appendix R requires that one train of cables and equipment necessary to achieve and maintain safe shutdown be maintained f ree of fire damage by one of the following means:

(1) Separation of cables and equipment and associated non-safety circuits of redundant trains by a fire barrier having a 3-hour rating. Structural steel foming a part of or supporting such fire barriers shall be protected to provide fire resistar.ce equivalent to that required of the barrier; (2) Separation of cables and equipment and associated non-safety circuits of redundant trains by a horizontal distance of more'than 20 feet with no intervening combustibles or fire hazards.

Tn addition, fire detectors and an automatic fire suporession system shall be installed in the fire area; or (3) Enclosure of cable and equipment and associated non-safety circuits of one redundant train in a fire barrier having a 1-hour rating.

In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area.

If these conditions are not met.Section III.G.3 requires an alternative shutdown capability independent of the fire area of concern.

It also reouires a fixed fire suppression system to be installed in the fire area of concern if it contains a large concentration of cables or other combustibles. These alternative requirements are not deemed to be equivalent; however, they provide equivalent protection for those configurations in which they are accepted.

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III.

By letter dated May 31, 1985, the licensee submitted the results of their Appendix R fire hazards analysis reevaluation for Unit No. 1, dated May 1985 for review. The licensee contends that the reevaluation was prompted by the

. interpretations to Appendix R promulgated in IE Notice 84-09 and Generic Letter 83-33. Therefore, based on the results of this. reevaluation the licensee requested twenty-seven additional exemptions from the specific provisions of Section III.G of Appendix R for certain fire areas in Unit No.1. ' Prior to the fire hazards analysis reevaluation, the Comission had granted only one. exemption on December 30,'1983, for certain system cables or components located within the containment buildings of Unit No. 1.

The Commission also granted an exemption on November 19, 1985, for certain shared fire areas of Unit No. I with fire areas for Unit Nc. 2 after the fire hazards analysis reevaluation.

The licensee identified twenty-seven specific fire areas which would require exemptions based on their reevaluation of Unit No. I fire areas.

Based on our review of the licensee's submittal as well as site visits by the Region II assigned fire protection engineer and the assigned NRR Project Manager, we issued a safety evaluation finding that the licensee's

' alternate fire protection configuration in twenty-two of the twenty-seven fire areas where exemptions or modifications were requested represents an equivalent level of safety to that achieved by compliance with Section III.G of Appendix R,10 CFR 50. The remaining five exemptions required further review of the additional justifications provided by the licensee by letter dated October 18, 1985. An attachment to this safety evaluation discusses V

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'. the remainino five fire areas. The alternate fire protection configurations

'in these areas also represent an equivalent level of safety to that achieved by compliance with Section III.G of Appendix R,10 CFR 50.

By letter dated July 16, 1986, the licensee provided information relevant to the "special circumstances" finding required by revised 10 CFR 50.12(a)

(see 50 FR 50764). The licensee stated that the existing and proposed fire protection features at Farley, tinit I accomplish the :nderlyir.g purpost of the rule.

Implementino additional modifications to provide additionel suppression systems, detection systems and -fire barriers to comply with Appendix R for all areas of the plant would reouire the expenditure of engineering and construction resources as well as the associated capital costs which would represent an unwarranted burden on the licensee's resources.

Costs that would be incurred are as follows:

Engineering, procurement and installation of additional piping, sprinkler heads, and supporting structures.

Engineering, procurement and installation of additional fire l

barriers, supports, suoport protection and ongoing-maintenance.

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Significant rerouting of power cabling and associated conduits.

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ducts and supports.

Increased surveillance on new or extended fire suppression and fire j

detection systems.

Increased congestion in numerous plant locations complicating future plant modifications / operations.

The licensee stated that these costs are significantly in excess of these reouired to meet the underlying purpose of the rule. The staff concludes b-o--______________

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.; 4 th'at "special circumstances" exist for the licensee's requested exemptions in that application of the regulation in these particular circumstances is not necessary to achieve the underlying purpose of Appendix R to 10 CFR Part 50.

(see 10 CFR 50.12(a)(2)(ii)).

IV.

Accordingly, the Commission has determined pursuant to 10 CFR,Part 50.12(a),

that these twenty-seven technical exemptions discussed in Section III are authorized by law and will not endanger life or property or the common de'ense and security, and is otherwise in the public interest. The Commission hereby approves the twenty-seven requested exemptions from Appendix R of 10 CFR 50 Section III.G as specifically identified in the Safety Evaluation dated September 10, 1986, which is available for public inspection at the Commission's Public Document Room, 1717 H Street, N.W., Washington, DC, and at.the Local Public Document Room, located at the George S. Houston Memorial Library, 212 W. Purdeshaw Street, Dothan, Alabama.

Pursuant to 10 CFR 51.32, the Commission has determined that the issuance of the Exemption will have no significant impact on the environment (51 FR 32151, dated September 9,1986).

This exemption is effective upon issuance.

FOR THE NUCLEAR REGULATORY COMMISSIOF Thomas M. Novak, Acting Director Division of PWR Licensing-A Office of Nuclear Reactor Regulation Dated at Rethesda, Maryland this' 10thday of September, 1986 a.

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