ML20216J972
| ML20216J972 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 03/12/1998 |
| From: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20216J976 | List: |
| References | |
| NUDOCS 9803240131 | |
| Download: ML20216J972 (3) | |
Text
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Dave Morey Ssuthern Nuclear Mce President Operatmg Company Fcriey Project P0. Box 1295 Birmingham, Alabama 35201 Tel 205.992.5131 March 12, 1998 SOUTHERN L Docket Nos.
50-348 COMPANY
$0-364 Energy ro Serve YourWorld" U. S. Nuclear Regulatory Commission A T f N.: Document Control Desk Washington, DC 20555 Joseph M. Farley Nuclea Diant Response to Reauest for Additional Information Reh.ted to Kaowool Fire Barriers Ladies and Gentlemen:
This letter is in response to the Nuclear Regulatory Commission's " Request for Additional Information Related to Knowool Fire Barriers - Joseph M. Farley Nuclear Plant, Units 1 and 2,"
dated December 24,1997, that was received by Southem Nuclear Operating Company (SNC) on January 5,1998.
SNC believes that the Kaowool as installed at Farley Nuclear Plant (FNP) will perform its intended design function and is an acceptable, approved raceway fire protection barrier. The attached enclosures are SNC's response and provide additional information relative to our raceway fire protection barrier. The Kaowool at FNP has a lengthy and unique history. Herefore, we believe a meeting to discuss its history, actions taken, and future plans would be beneficial for SNC and NRC staff.
This response contains no new commitments for Farley Nuclear Plant.
If you have any questions, please advise.
Respectfully submitted, b h brL<
Dave Morey
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Enclosures - Executive Summary SNC Response to NRC Request for Additional Information Related f
to Kaowool Fire Barriers - Joseph M. Farley Nuclear Plant, Units I and 2 Y
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Mr. L. A. Reyes, Region 11 Administrator - w/l Enclosure
.h Mr. J.1. Zimmerman, NRR Project Manager - w/ 2 Enclosures LAD
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Mr. T. M. Ross, Plant Sr. Resident inspector - w/l Enclosure ft.k I J
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SUMMARY
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The enclosed document is SNC's response to NRC's request for additional information related to Kaowool fire barriers installed at Farley Nuclear Plant.
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SNC implements the NRC " defense in depth" fire protection concept that relies on protecting i
safe shutdown functions by achieving a balance among three echelons or levels of protection:
- 1) fire prevention activities,2) the ability to rapidly detect, control, and suppress a fire, and 3) physical separation of redundant safe shutdown function <
- is is the basis for providing a Kaowool raceway fire protection barrier at Farley Nuclear Plant (FNP) on one r' ndant safe shutdown cable when minimum separation is not achieved. The Kaowool blani st's critical function is to provide a barrier protecting the enclosed cables from direct flame or hot gases in the event of a fire to delay heating of the cables to allow fire suppression measures to suppress the fire preventing loss of function of the cables.
Although documented evaluations specifically requested in the subject RAI can be performed, to do so would be burdensome, redundant to the efforts performed by numerous fire protection experts as documented in the references and is not required by FNP's licensing basis require-ments.
Kaowool was selected and initially installed at FNP between 1979 and 1980. A significant amount of testing and analysis had been conducted on Kaowool prior to and during that time, including the tests later referenced by NRC in IN 93-40, and IN 93-41. This testing involved numerous fire protection experts from across the country. There is evidence of NRC review and discussion of test results and documentation that the NRC accepted Babcock and Wilcox (B&W) test data to substantiate a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rating availability with the Kaowool product enclosing cable trays. Based on several presentations and verbal discussions with the manufacturer, B&W (now Thermal Ceramics), and with an understanding of Kaowool derived from the signifi-cant number of tests that had been conducted, the FNP design basis for raceway wrap was established.
Kaowool installations were recognized by NRC as not being bounded by fire tests for every conceivable configuration. However, with the data available to support the viability of Kaowool as a raceway wrap material, sound engineering judgment was employed to develop design in-Exrcunvr Suneauury Page1
stalittion d trils for construction of tha wrap ass mblics. The d3 sign:rs cnd revi: wars wera very knowledgeable, in the early 1980's, of the Kaowool material, its application, and the safety significance of its use at FNP. No formal, configuration-specific engineering evaluations sup-porting the fire resistive rating of the fire barriers were documented by FNP at that time, nor were any required. However, evaluations did take place in the form of verbal discussions, physical plant walkdowns & inspections, and documented correspondence. The evaluations culminated in summary descriptions of the installed conditions which were then submitted to NRC for review (and subsequent approval) via exemption requests. Raceway fire barrier modi-fications as described in these exemption requests were completed by November 1985.
The intended purpose of the exemption requests was to gain NRC approval of FNP's compli-ance with the requirements of Appendix R. This included not only approval of the operations methodology for fire response and controlling safe shutdown of the plant, but approval of the technical aspects of the fire protection systems, including the fire barrier installations as de-signed for the plant. The fire protection SERs received from the NRC in 1985 & 1986 docu-mented NRC approval of FNP's Asppendix R exemption requests. As Kaowool fire barrier instal-lations at FNP were approved via NRC SERs in response to Appendix R exemption requests, no additional documentation was necessary or required. These NRC approved Appendix R ex-emption requests for FNP were incorporated into the FNP FSAR.
SNC has identified over the years various inaccuracies, inconsistencies, and other errors in the FNP exemption requests included in the FNP FSAR. SNC is developing revisions to these ex-emption requests and currently plans to submit them for NRC review at a later date.
Our opinion that the Kaowool installed as the raceway fire protection barrier at FNP will perform its intended design function is based on an understanding of Kaowool and its performance characteristics derived from a significant amount of testing conducted by numerous fire protec-tion experts across the nation, and from discussions, presentations, and meetings with the i
manufacturer and other industry experts, and the use of engineering judgment by qualified fire l
protection engineers.
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