ML20054H741

Requests Exemptions from 10CFR50.48 & 10CFR50,App R Re Previous Commitments to Complete Fire Protection Mods,Forced Outages & Present Containment Fire Protection Measures,Per Util 810319,0623,820128 & 0420 Ltrs.Detailed Request Encl

ML20054H741
Person / Time
Site:	Farley
Issue date:	06/18/1982
From:	Clayton F ALABAMA POWER CO.
To:	Varga S Office of Nuclear Reactor Regulation
References
NUDOCS 8206240381
Download: ML20054H741 (11)

Text

. Malling Address

, Alabama Power Company 600 North 18th Street Post Office Box 2641 Birmmyam, Alabama 35291 Telesnone 205 783-6081

r. L. Clayton, Jr.

07,'J2"',"l' "' Alabama Power itv sout!cm o*tirc system June 18, 1982 Docket No. 50-348 50-364 Director, Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Mr. S. A. Varga Farley Nuclear Plant - Units 1 and 2 Fire Protection Upgrade Response to 10CFR50.48 and 10CFR50 Appendix R Requirements Gentlemen:

Alabama Power Company previously submitted a plan and sched-ule, including requests for exemptions, to satisfy the requirements of 10CFR50.48 (c)(5). These actions were contained in letter dated March 19, 1981, Attachment 2 and clarified by letter dated June 23, 1981. Other ' exemptions were subsequently requested in letters dated January 28 and April 20, 1982.

Alabama Power Company has completed a review of the Appendix R requirements with respect to: (1) the previous commitments to complete the fire protection modifications; (2) forced outages occurring on both units; and (3) present containment fire protec-tion measures. As a result of this review additional exemptions are required. These exemptions are specifically requested and justified in Attachments 1, 2, and 3 appended hereto.

The exemptions, pursuant to 10CRF50.12, from the applicable requirements of 10CFR50.48 and 10CFR50 Appendix R requested in the attachments can be summarized as follows:

A. Installation of modifications for both Units 1 and 2 to satisfy Section III.G.3 of }(()Ci)(

Appendix R will be scheduled, on each re-spective unit, for an outage of suf ficient duration to complete the planned modifica-tions. This outage will follow the first refueling outage occurring at least 240 days after the NRC approval of the asso- l ciated design descriptions (see Attachment 1).

8206240381 820618 PDR ADOCK 05000348 F PDR

Mr. S. A. Varga June 18, 1982 Director, Nuclear Reactor Regulation Page 2 U. S. Nuclear Regulatory Commission B. Installation of Unit 2 modifications that require a plant shutdown to satisfy Sections III.G.1, III.G.2 and III.0 of Appendix R will be scheduled for an outage of suf ficient duration to complete the planned modifications occurring at least 180 days from the initial refueling outage on this unit. The initial refueling outage is currently scheduled for the last quarter of 1982 (see Attachment 2).

C. Installation of Unit 1 modifications to satisfy Section III.0 of Appendix R will be scheduled for the first outage of sufficient duratien to complete the planned modifications. An outage meeting these requirements is currently sched-uled for March 1983 (see Attachment 2).

D. Installation of modifications to the present cont a in.nent fire protection systems to satisfy III.G.0 of Appendix R can be obviated based on a morr. thorough review of the fire hazards in c ontr.i nmen t (see Attachment 3).

E. In the event that unforeseen circumstances occur beyond the control of Alabama Power Company, partial installation of the modifica-tions will be implemented to the extent possi-ble during the outage scheduled for their completion to satisfy Items A, B and C. The completion of such modifictions will then be completed during the next outage of sufficient duration to complete the modifications (see Attachments 1 and 2).

Table 1 to this letter presents the revised plan and schedule to implement the modifications necessary to satisfy the provisions of Appendix R and reflects the aforementioned exemptions. For the completion of certain activities associated with modifications that require a plant shutdown, Table 1 provides the scheduled refueling outages and anticipated outage dates during which the modifications would be implemented. Table 2 provides the anticipated outage schedule for both Units 1 and 2 and is the basis for the schedule in Table 1.

Mr. S. A. Varga June 18, 1982 <

Director, Nuclear Reactor Regulation U. S. Nulcear' Regulatory Commission Page 3 j If you have any questions concerning these matters, please contact this office.

Yours very truly, d4]

F. L. Claytod, Jr.

FLCJr/ MAL:Jc-09 Attachments cc: Mr. R. A. Thomas (w/ attachments Mr. G. F. Trowbridge (w/ attachments Mr. J. P. O'Reilly (w/ attachments Mr. E. A. Reeves (w/ attachments Mr. W. H. Bradford (w/attachemnts)

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ATTACHMENT 1

Clarification of Installation Schedule for Alternative or Dedicated Shutdown Capability In accordance with 10CFR50.48(c)(5), Alabama Power Company sub-mitted a plan and schedule to satisfy the provisions of Appendix R in letter dated March 19, 1981, which was clarified by letter dated June 23, 1982. Attachment 2 to the March letter indicates that the complete installation of modifications to satisfy Section

!!!.G.3 of Appendix R are scheduled for April 1, 1984 (refueling outage number five for Unit 1) and February 8,1984 (refueling i outage number two for Unit 2). These dates, as stated in that letter, were predicated upon NRC review and approval of the associated design description and were intended to provide for a suf ficient duration to complete the final design and procurement and for two scheduled refueling outages to install the modifica-i tions following the NRC's approval. The basis for this schedule

is as follows:

1) No final design and procurement activities would be iniciated until receipt of NRC approval of the associated design descrip-tions.

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2) Control panels and relay cabinets that inter-f ace with Class 1E components would require design, field f abrication, and seismic test-ing prior to installation.

, 3) Material deliveries of critical items, such i as cable, would be expedited by initiating procurement during the initial stages of the final design.

i Alabama Power Company has held discussions with the NRC Staff t'het l indicated NRC approval of the design description may not be i granted within the time period originally anticipated in the l

preparation of the plan and schedule provided in the March 19, i 1981 letter. It is therefore necessary to clarify the Appendix R plan and schedule as shown on the attached Table 1.

Consequently, an exemption is requested, pursuant to 10CFR50.12, from the requirements of 10CRF50.48(c)(4) to allow the > '

l implementation dates for the installation of modifications for both Units 1 and 2, needed to satisfy Section III.G.3' of Appendix R to 10CFR50, be extended from the dates currently establishad by letter dated March 19, 1981, for each respective unit, to an i outage of sufficient duration to complete the modifications that is subsequent to the first refueling outage occurring at least 240 t days af ter the NRC approval of the associated design descriptions;

! or in the event that unforeseen circumstances occur beyond the l

control of Alabama Power Company that would allow.only partial l

• i 1 ATTACHMENT 1 Alternative or Dedicated Shutdown Page 2 l

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l completion of the installation of. such modifications to the extent possible within the critical path of the outage scheduled for  ;

i their completion, the installation of such modifications will be

implemented during the next outage of sufficient duration to

complete the modifications.

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ATTACHMENT 2 Rescheduling of Modifications Attributed to Forced Outages Alabama Power Company has submitted a plan and schedule identi-fying requested exemptions to satisfy the requirements of 10CFR50.48 (c)(5) in Attachment 2 of letter dated March 19, 1981, which was clarified by letter dated June 23, 1981. These commit-ment dates were predicated on the anticipated outage schedules presented in Attachment 1 of the March 19, 1981 letter. Since the establishment of these commitment dates, Units 1 and 2 have each experienced an unforeseen, forced outage.

Alabama Power Company has completed its assessment of the impact of the untimely outages concerning this subject and has determined that the Unit 2 modifications that require an outage to satisfy Sections III.G.1, III.G.2, and III.0 of Appendix R can not be completed in accordance with the original schedule of the March 19, 1981 letter. For these modifications, a required contractor's walkdown was to be performed during the two-week turbine-generator inspection and maintenance outage scheduled for early April 1982.

The need for this outage was precluded by the untimely Unit 2 outage occurring in late January 1982. At that time, the unplan-ned outage was not anticipated to be of sufficient duration to support the contractor's walkdown, and, therefore, the contrac-tor's walkdown was rescheduled to the next scheduled outage (i .e.,

refueling outage number one). Since the contractor's walkdown is required in order to complete the design and initiate procurement, refueling outage number one will not be of sufficient duration to complete the walkdown as well as the final design, procurement and installation of the associated modifications. The installation of Unit 2 modifications that require an outage to satisfy Sections III.G.I. III.G.2 and III.0 of Appendix R are now scheduled for an outage of suf ficient duration to complete the modifications occur-ring at least 180 days subsequent to ref ueling outage number one, which is currently scheduled for the last quarter of 1982.

The basis for requiring more than one outage to complete these activities is described in Attachment 2, page 2 of letter dated March 19, 1981.

As stated in letter dated December 22, 1981 Enclosure 7, Item 13, Alabama Power Company was unable to complete the installation of Unit 1 modifications to satisfy Section III.0 of Appendix R due to an unforeseen, forced outage occurring prior to the completion of the final design and procurement as scheduled in Attachment 2 of letter dated March 19, 1981. Partial installation of the planned modifications was completed based on the extent of available design and material. The remaining portions of the Unit 1 modifi-cations to satisfy Section III.0 of Appendix R are now scheduled for installation during the first outage of suf ficient duration to complete the planned modifications. This outage is currently scheduled for March 1983.

Attach:snt 2 Rescheduling of Modifications Page 2 Consequently, exemptions are requested, pursuant to 10CFR50.12, from the following requirements of 10CFR50.48(c)(3):

1. That the implementation dates for the installation of Unit 2 modifications that do require plant shutdown needed to satisfy Sections III.G.1, III.G.2 and 111.0 of Appendix R to 10CFR50 be extended from the date currently established by letter dated March 19, 1981 to an outage of sufficient duration to complete the planned modifications, occurring at least 180 days sub-sequent to refueling outage number one; or in the event that unforeseen circumstances occur beyond the control of Alabama Power Company that would allow only the partial completion of the instal-lation of such modifications to the extent pos-sible within the critical path of the outage scheduled for their completion, the installation of such modifications will be implemented during the next outage of suf ficient duration to complete the modifications.

2. As previously intended by letter dated December 22, 1981 and hereby restated, that the implemen-tation dates for the installation of modifica-tions to Unit No. I needed to satisfy Section III.0 of Appendix R to 10CFR50 be extended from the date currently established by letter dated March 19, 1981 to the first outage of suf ficient duration to complete the planned modifications; or in the event that unforeseen circumstances occur beyond the control of Alabama Power Company that would allow only the partial completion of the installation of such modifications to the extent possible within the critical path of the outage scheduled for their completion, the installation of such modifications will be implemented during the next outage of suf ficient duration to complete the modifications.

ATTACHMENT 3 Assessment of Present Containment Fire Protection Measures Alabama Power Company has completed the design analyses of the present fire protection measures for cables and equipment located in the containments of both Units 1 and 2. Alabama Power Company has determined that these present fire protection measures are adequate to provide a reasonable assurance of fire prevention and, in the highly unlikely occurrence of a fire in the containment, to ensure limited fire damage to cables and equipment essential to bring the plant to a safe shutdown condition. Therefore, the modifications required by Appendix R would not appreciably enhance fire protection safety at the Farley Nuclear Plant.

The present fire protection measures provide safeguards against the only significant combustibles located inside the containments of Units 1 and 2 (i.e., cable insulation and reactor coolant pump lubrication oil). Transient combustibles are administrative 1y controlled and are not found within the containments during normal operation. The assurance that such debris is not located in the containment during normal operation is provided by visual inspec-tion required by Technical Specifications (4.5.2.c). The present fire protection measures consist of the following four entities for protection of cables and equipment located in the containment:

1. In accordance with 10CFR50 Appendix R, the reactor coolant pump oil collection systems are being upgraded to meet seismic requirements to prevent the occurrence of a fire during all normal and design basis events.

2. As provided by purchase specifications, cable is adequately designed and tested as a flame re-tardant to satisfy the requirements of IEEE-383-1974, Standard for Type Test of Class IE Elec-tric Cables, Field Splices, and Connections for Nuclear Power Generating Stations. Addition-ally, the insulation of the cables would not be capable of sustaining combustion since protrac-tive faulted conditions would be interrupted by protection against overcurrent conditions.

3. Administrative procedures, utilizing documented inspections, ensure that all transient combusti-bles are removed from the containment prior to the establishment of containment integrity during the plant startup sequence. Under normal power operation, personnel are not routinely allowed to enter the containment; and, there-fore, transient combustibles are not introduced into the containment. Personnel do enter the containment in unusual instances at power; however, all transient combustibles

Attachment 3 Fire Protection Measures Page 2 that are introduced into the containment are minimized, and containment areas are fully inspected for fire hazards prior and subse-quent to task completion.

4. Fire fighting procedures are used by the Farley Nuclear Plant Fire Brigade to imple-ment the use of plant fire protection systems, such as the fire hose stations located in the containment, which were installed to ensure limited fire damage to cables and equipment important to safety in

the highly unlikely occurrence of a contain-ment fire. The locations of the containment fire hose stations were selected to provide sufficient fire suppression at the electrical penetrations, pressurizer area, and outside shield wall.

1 Alabama Power Company has determined that these present fire i protection measures employed at Farley Nuclear Plant are adequate to provide fire protection of cables and equipment essential to achieve a safe shutdown condition and satisfy the objective of Section III.G.2 of Appendix R.

Consequently, an exception is requested, pursuant to 10CFR50.12, from the requirements of Section III.G.2 of Appendix R to 10CFR50 to allow the obviation of the need for the installation of modifi-cations for both Units 1 and 2 to the present containment fire protection measures.

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TABLE 1 .

PLAN AND SCHEDULE FOR FIRE PROTECTION PROGRAM 10CFR PART 50.48 AND PART 50. APPENDIX R Design Schedule Completion Dates Contractor Schedule Completion Dates DESIGN FINAL FNP PREPARATION ANALYSIS AND PREPARATION SU8MITTAL DESIGN 10CFR50 UNIT FOR OF CONTRACTOR FOR OF DESIGN AND INSTALLATION APPENDIX R NO. WALKDOWN WALKDOWN WALKDOWN SELECTION WALKDOWN WALKDOWN DESCRIPTION PROCUREMENT COMPLETE III.G.2 1 5-1-81 6-1-81 8-1-81 9-1-81 10-1-81 11-1-81 N/A 12-1-81 5-1-82 (and no outage III.G.1) required 1 11-1-81 3-1-82 8-1-82 9-1-82 12-1-82 Refueling N/A 8-1-83 Refueling Outage outage Outage No. 5 (4-1-84)#

required No. 4 (03-21-83)#

2 4-1-81 6-1-81 5-15-82 6-15-82 7-1-82 7-15-82 N/A 9-1-82 2-8-83 no outage required Refueling Outage 2 4-1-81 6-1-81 3-1-82 4-1-82 9-15-82 Refueling N/A 6-1-83 No. 2 (12-12-83)#

outage Outage required No. 1 (11-29-82)#

III.G.3 1 11-1-81 3-1-82 8-1-82 7-1-82 Eight months

• Second outage

• following following NRC approval NRC approval 2 4-1-81 6-1-81 5-15-82 7-1-82 Eight months

• Second outage

• following f oll owing NRC approval NRC approval III.0 1 10-1-81 Refueling Dutage No. 4 (03-21-83)#

N/A N/A Refueling Outage 2 9-1-83 No. 2 (12-12-83)#

'* Prsdicated upon NRC review / approval of the design description and integration into scheduled outages.

fTh3 dates in parenthesis reflect the current outage schedule provided in Table 2.

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