ML20236R570

Responds to NRC Re Violations & Deviations Noted in Insp Repts 50-313/87-14 & 50-368/87-14.Corrective Actions:Restrictions Will Be Placed on Live Load Capacities of Elevations 372 & 386 Ft

ML20236R570
Person / Time
Site:	Arkansas Nuclear
Issue date:	10/30/1987
From:	Levin J ARKANSAS POWER & LIGHT CO.
To:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20236R531	List: IR 05000313/1987014 ML20236R570
References
0CAN1O8709, CAN1O8709, NUDOCS 8711230363
Download: ML20236R570 (5)

Text

l

r.  : TI@ EDWE A NOV 5 587

.)

ARKANSAS POWER & LIGHT COMPANY October 30, 1987 ,

T l R@{M WXY.n NOV - 51967 BCAN108709 Mr. L. J. Callan, Director Division of Reactor Projects U. S. Nuclear Regulatory Commission j Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 ]

l

SUBJECT:

Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313/50-368 License No. DPR-51 and NPF-6 i Response to Inspection Report 50-313/87-14 and 50-368/87-14

Dear Mr. Callan:

J Pursuant to the provisions of 10CFR2.201, a response to the violation and one deviation identified in the subject inspection i report is submitted. The response to deviation 313-368/8714-02  !

will be submitted within 30 days of this response per discussions October 30, 1987, between Mr. Lomax of my staff and Mr. Murphy of your staff.

Sincerely, N

< .J. ~nn. Gisy J. M. Levine Executive Director Nuclear Operations i

l JML: PLM:djm Enciosure gcAs 29 - - - . . - - , . . . . . , . -

Notice Of Violation A. According to 10CFR50, Appendix R, paragraph III, G.2, one of the means  !

of ensuring that one of the redundant trains is free of fire damage is ]

to provide separation of cables and equipment and associated non-safety l circuits of redundant trains by a fire barrier having a 3-hour rating. I Structural steel forming a part of or supporting such fire barriers l shall be protected to provide fire resistance equivalent to that required of the barrier.

Contrary to the above, structural steel was found in Room 111 in Unit.1 and Rooms 2055 and 2084 in Unit 2 supporting a fire barrier and unprotected from the effects of a fire.

This is a Severity Level IV Violation. (Supplement I) (313/8714-01; j 368/8714-01) J i

Response To Violation 313/8714-01, 368/8714-01 (1) The Reason For The Violation If-Admitted:

AP&L agrees that the three rooms of concern were in a condition that did not meet the requirements of Appendix R and that no exemption had been requested. These rooms had been evaluated based on fire area fuel loading and the maximum obtainable enclosure temperatures associated with these values. The use of this fire load - fire severity relationship to determine resistance required for fire barriers is considered by the National Fire Protection Association (NFPA) to provide conservative estimates. The original calculations to determine structural steel integrity under fire conditions did not consider the effects of localized heating due to the methods used to do these evaluations and the conservatism associated with the analysis.

(2) The Corrective Steps That Have Been Taken And The Results Achieved:

Prior to the Unit 1 inspection, AP&L contracted with Professional Loss Control, Inc. (PLC) to do an analysis of localized heating. Their methodology had been accepted by the NRC Areas with potential localized l heat sources that did not have area-wide suppression or existing exemption requests were analyzed. The results indicated concerns in three rooms

- 2055, 2084, and 111. Rooms 2055 and 2084 will have' portions of the I structural steel identified in the PLC report protected to provide a fire I resistive rating of three hours. Using PLC's localized heating analysis, AP&L conducted further reviews of the live loads on the structural steel in Room 111. As a result, restrictions will be placed on the live load capacities of elevation 372' (Room 111 itself) and on elevation 386' (above portions of Room 111) in order to ensure the integrity of the Room 111 ceiling and floor slabs assuming loss of the Room 111 structural steel support. With the solutions above, the structural steel forming l the parts of, or supporting such fire barrier, will be protected as  ;

necessary to provide the fire resistance equivalent to that required of  ;

the barrier. l l

I l

. _ . _ _ _ . _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ . _ _ _ . _ _ _ . _ _ . _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ .. _ J

.<4 , ,

I (3) The Corrective Steps That Will Be Taken To Avoid further Violations:

When design changes or fire loading indicates the need for analysis of 1 the requirements of Appendix R, the effects of localized heating.will {

be considered as necessary. These requirements will be included in j appropriate engineering procedures. <

l (4) The Date When Full Compliance Will Be Achieved:

Modifications discussed in section (2) above and procedure changes-discussed in section (3) above will be completed by March 1, 1988.

1 i

l I

i l

l i

i i

l-(3) ,he T Corrective Steps That Will Be Taken To Avoid Further Violations:

I Vtan design changes'or fire loading indicates the need for analysis of i tae requirements of Appendix R, the effects of localized heating will ,

be considered as necessary. These requirements will be included in j l appropriate engineering procedures.

(4) The Date When Full Compliance Will Be Achieved: ,

L Modifications discussed in section (2) above and procedure changes f discussed in section (3) above will be completed by March 1, 1988. I l

1 i

1 I

I l

l

^,. .

A NOTICE OF DEVIATION B. The licensee committed in the ANO Fire Protection Program, developed under the guidelines of Appendix A to BTP-APCSB 9.5-1, to install a fire alarm system in accordance with the provisions of National Fire Protection Association Standard No. 720, 1975.

In deviation from the above, the NRC inspector determined that the fire alarm system for Units 1 and 2 is not designed to annunciate subsequent trouble alarms (reflash) after an initial alarm is silenced.

(313/8714-03; 368/8714-03)

RESPONSE TO DEVIATION 313/8714-03; 368/8714-03 (1) The Reason For The Deviation If Admitted:

AP&L concurs it is in deviation from a previous licensee commitment regarding NFPA 720 (1975). NRC correspondence (1CNA027716) of February 22, 1977 (Item 33) requested AP&L to provide information concerning fire detector protective signal circuitry. The specific staff question was:

ITEM 33: Identify those fire detectors which protect safety-related equipment or are located in areas containing a potential fire hazard to safety-related equipment, whose protective signaling circuitry is not an NFPA Code 72D Class A System.

AP&L's response to the staff's question (ICAN097712) dated September 21, 1977, for Item 33 provided the following information.

All fire and smoke detectors and fire detection systems utilized at Arkansas Nuclear One for both fire alarm service and automatic system actuation are designed and installed in accordance with NFPA No. 72A, " Local Protection Signaling System", with Class B circuitry as defined in NFPA No. 72D, " Proprietary Protective Signaling Systems".

AP&L's response, as indicated above, clearly indicates the system was designed to NFPA 72A (1975) and only portions of NFPA 72D (1975). When the installation of the circuit supervision was completed, it did provide alarm lights on the fire papel for each subsequent trouble.

However, it did not provide the reflash of the audible alarm upon subsequent trouble annunciation in deviation from the requirements of NFPA 72D. The reason for this design discrepancy could not be determined. Although not previously identified as a deviation from an NRC commitment, this lack of audible reflash capability was identified by AP&L prior to the Appendix R audit as a human engineering deficiency as a part of AP&L's CRDR in response to NUREG 0737, Item I.D.1.

1

?

(-*. . .

Therefore, modifications of the system design to incorporate the audible reflash capability were in progress at the' time of the inspection.

(2) The Corrective Steps That Have Been Taken And The Results Achieved:-

A design change has been initiated to include reflash capability-for both control room panels circuit supervision. The modifications should be completed for Unit I during the IR8 refueling outage and for Unit 2 during the 2R7 outage.

(3) The Corrective Steps That Will Be Taken To Avoid Further Deviations:

In addition to the design changes for reflash capability, the-requirements of NFPA 720 (1975) for Class B supervision are being reviewed to. determine if any additional changes are necessary.

(4) The Date When Full Compliance Will Be Achieved:

The modifications should be completed for Unit 1 by December 1,1988 during the IR8 refueling outage and for Unit 2 December 1, 1989 during the 2R7 outage.

)

-l 4

_ _ _ _ - - _ _ -