ML20214M265

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Forwards Request for Addl Info Re 840815 & 850830 Requests for Exemption from App R Requirements.Requests Info Be Provided within 45 Days from Ltr Receipt
ML20214M265
Person / Time
Site: Arkansas Nuclear  
Issue date: 09/03/1986
From: Knighton G, Stolz J
Office of Nuclear Reactor Regulation
To: Campbell G
ARKANSAS POWER & LIGHT CO.
References
NUDOCS 8609110030
Download: ML20214M265 (6)


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S:ptembsr 3,1986 Docket No. 50-313 50-368 Mr. Gene Campbell Vice President, Nuclear Operations Arkansas Power and Light Company P. O. Box 551 Little Rock, Arkansas 72203

Dear Mr. Campbell:

We are continuing our review of your Appendix R exemption requests for Arkansas Nuclear One, Units 1 and 2, of August 15, 1984 and August 30, 1985.

We visited the plant on August 21, 1986, to obtain more information concerning your exemption requests. As a result of our review and our recent visit to the plant we have determined that we need additional information._ The enclosed Request for Addition Information identifies the information which is needed to complete our review.

Please provide the requested information within 45 days from receipt of this request.

The reporting and/or recordkeeping requirements of this ietter affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.

Sincerely, sU

.4 John F. Stolz, Director PWR Project Directorate 6 Division of PWR Licensing-B

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George W. Kn) ton, Director PWR Project Directorate #7 Division of PWR Licensing-B

Enclosure:

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Mr. G. Campbell Arkansas Power & Light Company Arkansas Nuclear One, Unit I cc:

Mr. J. Ted Enos, Manager Nuclear Engineering and Licensing Arkansas Power & Light Company i

P. O. Box 551 l

Little Rock, Arkansas 72203 Mr. James M. Levine, Director Site Nuclear Operations Arkansas Nuclear One P. O. Box 608 Russellville, Arkansas 72801 Mr. Nicholas S. Reynolds Bishop, Liberman, Cook, Purcell & Reynolds 1200 Seventeenth Street, N.W.

Washington, D.C.

20036 Mr. Robert B. Borsum Babcock & Wilcox Nuclear Power Generation Division Suite 220, 7910 Woodmont Avenue Bethesda, Maryland 20814 Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 2090 Russellville, Arkansas 72801 Regios,a1 Administrator, Region IV U.S. Nuclear Regulatory Commission Office of Executive Director for Operations 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Mr. Frank Wilson, Director Division of Environmental Health Protection Department of Health Arkansas Department of Health 4815 West Markham Street Little Rock, Arkansas 72201 Honorable William Abernathy County Judge of Pope County Pope County Courthouse Russellville, Arkansas 72801

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Request for Information (RFI)

Appendix R Exemption Request Arkansas Nuclear One Units 1 and 2 Docket Numbers 50-313 and 50-368 The following information is needed to evaluate the Appendix R Exemption Requests made in the Licensee's letters dated August 15, 1984 and August 30, 1985.

NOTE:

1.

Unless otherwise noted, page numbers in this RFI refer to those of the Li*censee's August 30, 1985 submittal.

2.

Questions 280.1 through 280.8 are reproduced from the previous RFI issued on July 25, 1986.

Questions 280.9 through 280.19 are additional questions generated during th plant site visit on August 21, 1986.

This RFI, therefore, combines previous and new questions to make it comprehensive.

280.1 On Page 4, the Licensee requested exemption from the requirement for 20 feet of separation for the diesel generator exhaust fans (ANO-1 and ANO-2).

Page 5 describes proposed modifications including 3-hour fire rated conduit wraps, walls between redundant fans, and the reroute of power cables so that louvers are powered from vital power sources.

To facilitate the staff.'s review, provide the following:

a.

Clarify the intent of the requested exemption from 20 feet of separation given the proposed modifications are implemented.

b.

Discuss the fire resistance capability of the proposed wall (s) separating redundant diesel generator exhaust 3 fans for both units.

280.2 On Pages 4 and 31, exemptions are requested for the omission of structural steel coatings or 3-hour barriers (as roofs) of various fire zones of Units 1 and 2.

Generic Letter 86-10 dated April 24, 1986 provides guidance regarding exterior walls and their penetrations.

" Exterior walls and their penetrations should be qualified as rated barriers when (1) they are required to separate a shutdown-related division (s) inside the plant from its redundant (alternate)

4 counterpart outside the plant in the immediate vicinity of the exterior wall, (2) they separate safety related areas from nonsafety related areas that present a significant fire threat to the safety related areas, or (3) they are designated as

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a fire barrier in the FSAR or FHA.

Usually exterior walls are designated as a fire area boundary; therefore, they are evaluated by the guidelines of Appendix A.

A FHA should be performed to determine the rating of exterior walls if required by the above criteria."

To facilitate the staff's review, provide additional information regarding these roofs considering the guidance of Generic Letter 86-10 as described above.

280.3 Numerous exemptions from the requirements of Section III.G.2.a of Appendix R are requested for fire area boundaries comprising of fire barriers and fire barrier components.

l Section III.G.2 of Appendix R contains requirements for fire protection within fire areas.

It does not apply to fire area boundaries.

Acceptable guidelines for j

establishing fire area boundaries are set forth in Appendix A to BTP APCSB 9.5-1 in Section D.1. (j).

I For each exemption request for fire area boundaries, confirm that the exemptions from Section III.G.2.a of Appendix R are required or if deviations from the guidelines of Appendix A are sought.

280.4 On Page 8, the Licensee requests exemption for omission of automatic suppression capability for the EFW pump room (Zone 38-Y), and less than 20 feet separation between the EFW pumps P7A and P7B.

To facilitate the staff's review, provide the following:

a.

Provide the spatial separation between the turbine-driven EFW pump P7A and the motor-driven EFW pump P7B, including a description of intervening combustibles, fire hazards, and fire loads.

b.

Provide a detailed description which clearly illustrates the arrangement of installed automatic detection.

The information should, as a minimum, include location of detectors relative to ceiling height, HVAC registers, exposed ceiling beams and other ceiling projections, and the pumps.

c.

On Page 17, it is stated that P7A, the steam-driven EFW pump, could be manually operated if its control cable was destroyed by fire.

Describe the actions

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required to manually operate the pump, time needed and time availble for such actions and sequence of such actions related to the consequences.of a fire in this zone.

d.

Describe the fire separation of Fire Zone 38-Y from the remaining portions of Fire Area C.

280.5 On Page 8, an exemption from suppression for makeup conduit with 1-hour wrap in Fire Zone 31-Y is requested.

Provide a technical basis for acceptability which demonstrates that the level of fire protection provided is equivalent to the technical requirements of Section III.G.2.b of Appendix R.

280.6 Provide detailed descriptions to clearly illustrate the arrangement of all detectors in the main control room complex.

The information should, as a minimum, include location of detectors relative to ceiling height, HVAC registers, exposed ceiling beams and other ceiling projections and fixed combustibles.

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280.7 On Page 17, an exemption is requested for the omission of 3-hour rated coatings for structural steel supporting the ceiling of Zones 98-J and 112-I.

Verify that automatic suppression systems are installed throughtout these zones for all unprotected structural steel.

280.8 On Pages 39 and 43 of the August 15, 1984 submittal, exemptions from coating structural steel are requested l

based on maximum expected temperatures.

Provide a description of the methodology used to determine the maximum expected temperatures.

280.9 On various pages in the submittal, including Pages 2, 3,

6, 12, 13, 16, 26, 27, and 35, evaluations of various l

issues are mentioned.

Some of these evaluations are described as " ongoing."

In other cases, the evaluation method and relevant factors are described only very generally.

To facilitate the staff's review:

a.

Provide conclusions for those evaluations which have been completed 1

b.

Describe the method by which each evaluation was conducted and the relevant factors and specific terms including the fire loading in the fire zones, the location and arrangement of redundant hot shutdown components and cables, the fire protection features j

of fire zones or areas.

280.10 Provide the fire loading, in BTU per square foot, for each fire zone and fire area for which an exemption has been requested.

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280.11 -Identify all hot shutdown components and their redundant counterpart, by fire zone, in each of the fire areas for which an exemption has been requested.

280.12 Provide an updated description of the modifications proposed for the diesel generator exhaust fan. cables in Fire Zones 1-E and 2-E (Page 5).

280.13 Provide information on the normal and hot shutdown positions of the BWST outlet valves.

Also, describe when the valves will have to be operated.

280.14 Update the description of the fire door in the wall between Fire Zones 38-Y of Fire Area C and Fire Zone 46-Y of Fire Area B (Page 7).

280.15 Provide the location of both trains of makeup pump cables for Unit 1.

One train is located in Fire Zone 31-Y (Page 8).

280.16 Provide the locations of the control cables for the redundant emergency feedwater pumps (Page 8).

Provide the time when the emergency feedwater pump will be required considering a fire in the emergency feed water pump room.

280.17 Provide additional information on the locations of the valves for the Unit 2 makeup pumps located in Fire Zone 2084-DD (Pages 26 and 27) and indicate when the makeup pumps and valves will be needed.

280.18 Indicate the source and duration of the fuel supply for the security diesel described on Page 45.

280.19 On Pages 39 and 43 of the August 15, 1984 submittal, exemptions from coating structural steel are requested based on maximum expected temperatures.

Discussions at the site visit of August 21, 1986 indicate that localized heating effects of fires in cable trays beneath structural members were not considered.

Provide the t

results of additional evaluations considering this effect on structural steel.

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