ML20070E244
| ML20070E244 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 02/26/1991 |
| From: | Hairston W ALABAMA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20070E245 | List: |
| References | |
| GL-86-10, NUDOCS 9103050290 | |
| Download: ML20070E244 (10) | |
Text
_ - _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - - _ - _ .
i o
y 4 madama har Compnny 40 itwernen Cents huwty h>M O!fa e Dos 1?M (ntmmpham, Atabrim 3h001 wenhonecobut4Mn W. G. HairSwn. fil JEE-mL lCOsOZ"' Alabama Power February 26, 1991 er saw,,eg rpm Docket Nos. 50-348 50-364 U. S. Nuclear Regulatory Commission ATTN Document Control Desk Vashington, D. C. 20555 Gentlemen:
Joseph H. Farley Nuclear Plant - Units 1 and 2 Fire Protection Technical Specifications
,_ and License Condition Nuclear Regulatory Commission (NRC) Generic Letter 86-10. " Implementation of Fire Protection Requirements," dated April 24, 1986 requested that licensect incorporate into their FSAR the ftre protection program that has been approved by the NRC, including the fire hazards analysis and major commitments that form the basis for the fire protection program. Generic Letter 86-10 also states that, upon completion of this effort, the licensee may apply for an amendment to the operating license which amends any current license condition regarding fire protection and substitutes a standard license condition. As a result of the new license condition and the placement of the fire protection program in the FSAR vhere it is controlled via 10CFR50.59, Generic Letter 86-10 states that licensees may request a license amendment to delete the fire protection technical specifications that vill become unnecessary. Additional guidance for the preparation of a license mare ant request to implement Generic Letter 86-10 vas provided in NRC Generic Letter 88-12. " Removal of Fire Protrction a Requirements from Technical Specifications," dated August 2, 1988.
In accordance with Generic Letter 86-10, Alabama Pover Company incorporated the fire protection program into the July 1987 FSAR update as Appendix 9D. This appendix describes the program as approved by the NRC including the fire hazards analysis and major commitments that form the basis for the program. Alabama Power company has revieved the safety evaluations supporting fire protection reviews and 10CFR50, Appendix R exemptions to ensure that they are correct. During this review Alabama Power Company identified the need for a change to the justifications for exemption requests 1-038 for fire area 1-006 and 2-035 for fire area 2-006.
These changes are discussed in Attachment 1 to this letter. Vhile the conclusion for granting these exemptions has not changed, the original basis for the conclusion vas incorrect. Any necessary changes to the PSAR as a result of Alabama Power Company's reviev of the NRC Safety Evaluation Reports vill be made in the 1992 annual FSAR update. Consequently, Alabama
! power Company hereby submits the following proposed changes to the fire protection license conditions and the fire protection portions of the Technical Specifications in accordance with the guidance previd.'d in Generic Letter 88-12. phy/
9103050290 910226 y PDR ADOCK 0500034G lk A
l O. ( P PDR 1
s o' l c 4 U. S. Nuclear Regulatory Commission Page 2 The proposed changes include:
- 1. Revision of the fire protection license conditions 2.C.(4) for Unit 1 and 2.C.(6) for Unit 2 to provide consistency with the standard fire protection license condition contained in the NRC Generic Letter 86-10.
- 2. Deletion of Unit 1 and Unit 2 fire protection Technical Specifications 3/4.3.3.9, 3/4.7.11.1, 3/4.7.11.2, 3/4.7.11.3, 3/4.7.11.4, 3/4.7.11.5, 3/4.7.12, and associated bases.
- 3. Deletion of the minimum Fire Brigade staffirg requirement, Technical Specification 6.2.2(e), for both Units 1 and 2.
Vith regard to administrative control of the fire protection program, existing Technical Specification 6.5.1.6(b) requires that the Plant Operations Reviev Committee (PORC) review the safety evaluations for all programs required by Specification 6.0 and changes thereto.
Specification 6 8.l(f) requires that written procedures be established, implemented and maintained covering fire protection program implementation. Also, Specification 6.5.1.7(a) requires that the PORC recommend to the General Manager - Nuclear Plant in vriting, approval or disapproval of items considered under 6.5.1.6(b). Consequently, existing administrative controls are already in place in the Technical Specifications to ensure that the capability is preserved to achieve and i
maintain safe shutdown in the event of a fire. In regard to Technical Specification 3/4.7.11.1, Alabama Power Company vill make the appropriate administrative changes to plant procedures to include the shutdown and startup requirements of Sections 3.0.3 and 3.0.4 in the unlikely event of the loss of the fire suppression water system and failure to establish a backup vater supply within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Vith regard to reporting requirements, Alabama Power Company recognizes the obligation to notify the NRC of fire protection-deficiencies which meet the criteria of 10CFR50.72 and 10CFR50.73, as applicable.
The proposed changes to the Technical Specifications and license conditions are provided in Attachments 2 and 3, respectively. Alabama Power Company has determined that the proposed changes do not involve a significant hazards consideration. In accordance with 10CFR50.92, a significant hazards consideration evaluation is provided as Attachment 4.
The updated FSAR (Attachment C to Appendix 9B) contains the requirements that vill replace those that have been proposed for deletion f rom Technical Specification Sections 3/4.3 and 3/4.7 except the shutdovn requirement of Technical Specification 3.0.3 in the unlikely event of the loss of the fire suppression water system and failure to establish a backup water supply within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. As noted above, this shutdown requirement vill be incorporated into plant procedures. Section 9B.2.3.2 of Appendix 9B of the updated FSAR also discusses Fire Brigade staffing.
l l- .
l l
U. S. Nuclear Regulatory Commission page 3 Alabama Pover Company's Plant Operations Review Committee has ttviewed these proposed Technical Specifications changes and the Nuclear Operations Review Board vill reviev these proposed Technical Specification changes at a future meeting. It is requested that these proposed changes be approved by July 1, 1991. Since implemcntation of this proposed amendment vill require a significant number of administrative changes to procedures in order to convert Technical Specification based surveillance procedures into FSAR based surveillance ptocedures, it is requested that the proposed amendment become effective 90 days after NRC approval.
Alabama Power company also requests that the NRC staff review the attached proposed adjustment to the SERs supporting the fire protection reviev and exemptions from the requirements of 10CFR$0, Appendix R and issue corrected safety evaluations.
A copy of this letter and all applicable enclosures has been sent to Dr.
C. E. Fox, the Alabama State Designee, in accordance with 10CFR$0.91(b)(1).
If you have any questions, please advise.
RespectIully submitted, ALABAHA POVER COMPANY vrt ,~
~Vu . . llairston, III VGil,III /RVV t mV. 8.06 Attachments SVORN TO AND SUBSCRIBED BEFORE ME cc Mr. S. D. Ebneter Mr. S. T. Hoffman THIScNe Mr. G. F. Maxwell DAYOF/j..a,)<,1991.
C) f Dr. C. E. Fox ,
/ k'. t . p / w .
u(T~
n . Notaryfluhlic Hy Commission Expires: / V
/ 7
bei Hr. R. P. Mcdonald Mr. J. E. Garlington Mr. L. B. Long Mr. C. D. Nesbitt Mr. D. H. Morey Mr. J. V. McGovan Mr. D. J. Shelton Mr. T. T. Robin Mr. Scott Fulmer Commitment Tracking System (2)
A1TACllHENT 1 MARKED-UP PAGI S Pit 0M NRC SAFE 1T PVAuUATION RI! PORT POR APPENDIX R EXEMPTIONS TRANSMITTED llY 1.01TERS DATID SEPTEMBER 10, 1906 AND DI:CEMBER 29, 1986 AND JUSTIFICATIONS POR PROPOSED CIIANGES
- sEl &cnsmi&d by e&r l do/ed Sepnmber/4 M86 t9 b' e#is twahr ama kwwill Ime. 4he audita An analysis was performed to demonstrate that a fire imitid tv Uny Uf-the AF+tump room! 'ov!d act de%t-the miliery 'eedwater system. A i h e irr eny-one-of-the-pump-rooms =1d c!use-4heJosF of-one-AFW pump-end-AFWfb-g g A ene steam generator.
The AFW pump rooms are highly segregated watertight rooms with 2 feet thick l reinforced concrete walls and watertight doors that are maintained closed. '
Lubricating oil and cable insulation are the only combustibles present in l the pump rooms. Leaking oil would be contained within the individual rooms or would drain into the sump servicing the room. The combustible loading of I any one pump room is estimated to be less than 30,000 BTV/f t.: with a 1 maximum fire severity of less than 30 minutes.
A smoke detection system is installed in each of the three auxiliary feedwater pump rooms. The detection system would provide early warning of a fire, allowing the fire brigade adequate time to respond. A manual hose station, portable extinguishers, and portable smoke removal equipment are available for use in the area.
The room construction coupled with a low quantity of combustible material, the presence of smoke detection system, and the availability of equipment for use by the fire brigade ensures that a fire in om f thetAFW pump rooms would be confired to the affected roomA Such a fire wouldgot prevent (auxiliaryteedwaterflowtoatleastenesteamgenerator. Tra/n B mededriven in order to ensure that N r p g t Yrh M NOh#Mb[
compertment-to-another, the electrical penetrations have been sealed with firepenetrations and the resistive silicone mechanical foam. The pipe af U$[ec/e licensee has comitted to include these penetrations into their fire barrier surveillance program.
The compnnent cooling water (CCW) pump and heat exchanger room 185 is protected by an automatic smoke detection and sprinkler system. The licensee has committed to modify the sprinkler system, by the end of the Unit 1 seventh refueling outage, in the area of the CCW pumps to provide unobstructed sprinkler protection for the subject pumps. The combustible fire loading in the room is less than 35,000 BTV/f te with a maximum fire severity of less than 30 minutes. The detection system in the room would provide early warning of a fire allowing the fire brigade adequate time to f respond. A manual hose station, portable extinguishers, and portable smoke removal equipment are available for use in the area.
The CCW pumps are located on 21-ft. centers. Heat detectors are provided in the 5-kV CCW pump disconnect switch which alarms locally and in the control l room. The 5 kV disconnect switch cabinets are provided with a total-flooding CO: system that is activated by the heat detectors.
The CCW pump cables are wrapped with two 1 in. layers of kaowool with the exception of the train A cables for the swing CCW pump which are wrapped with a single 1-in, layer. All trains of CCW pump cables are covered by an automatic sprinkler system.
,% d a $re. oukde the 7' rain B mohr dria APW
+oom MSociakd wou/degwpmen not affect);fhe
/ raceways. Train 5 pump and H
l JUSTIFICATION FOR ADJUSTMENT OF NRC SAFETY EVAL.UATION 2
-FOR APPENDIX R EKEMPTIONS TRANSMITTED BY THE NRC LETTER DATED SEPTENBKR 10, 1986 Exemption request 1-30 for fire area 1 006 analyzed the Auxiliary Feedvater (AFV) pump rooms as separate zones within the fire a rer.. Subsequent to.the issuance of the requested exemption, alabama rover Company performed a review of the exemption *
. request to document the non-rated barriers which are required for Appendix R :=paration to maintain these pump rooms as separate zones. During this reviev, it was identified that the room cooler for the Train A motor driven AFV (MDAFV) pump room was located outside of the pump room. Thus, the exemption request was incorrect in its description of the components and the SER
-does not reflect the actual plant conditions. An evaluation of the as built condition grouped Zone 2 (vestibule area), Zone 3 (Train A MDAFV pump room), and Zone 5 (Turbine Driven AFV pump i
room) into one zone'and demonstrated that a fire outside Zone 4 (Train B HDAFV pump room) vill leave Train B MDAFV flow to at least one steam generator, and a fire inside Zone 4 vill not affect AFV flov from the Train A HDAFV pump or the turbine driven AFV pump. Therefore, AFV flov to at least one steam generator vil'1 be provided by the present configuration and would be unaffected by a fire in the area. This is consistent with the NRC's conclusion for granting the exemption in this area and reflects the as built configuration existing during the NRC valkdovn.
l
- . . - , _ _ , . . - , . , _ . . . . . . . . _ _ . . _ _ _ _ , _ _ _ . _ . _ . _ . . . _ _ . . - , _ . . . .-_._,-,_.,_u.,;__.._;a,.__..._..-.--,_
6ER $tDnsmlN le&Y c]O~ech Dec.em O6 r b) 00b Enclosure 43 Room 2236 0 0 Duct Chase Room 2241 3,869 Less than Main Steam 30 mins.
and Feedwater Valve Room Room 2242 1.287 Less than Pipe Chase 30 mint.
Room 2243 1,670 Less than l Pipe Chase 30 mins, i A-detection system covers the entire area except for rooms 2195, 2236, 2242, and 2243. Room 2167 has a wet-pipe sprinkler system which activates a local fire alarm bell trouble horn, and annunciates in the control room.
Automatic water suppression systems are provided for rooms 2189, 2190, 2194, and a portion of room 2185. The suppression system in room 2185 will be modified to provide direct, unobstructed coverage to the CCW pumps.
Heat detectors are provided in the 5-kV disconnect switch in room 2185 which I alarm both locally and in the control room. The 5-kV disconnect switch ;
cabinets are provide:i with a total flooding carbon dioxide system which is '
activated by the heat detecters. Two water hose stations, located in rooms '
2185 and 2189, are provided. A portable extinguisher is located in room 2185 outside of room 2167. A hose station in room 2234 (area 2-20) will be available for use in this area. Automatic water suppression systems are provided for rooms 2185, 2189, 2190, and 2194 to protect electrical cable from exposure fires.
The licensee justifies the acceptability of this exemption on the basis of the existing fire protection, their alternative shutdown actions, and their 1 proposed fire protection modifications associated with fire area 2-006.
10.3 EVALUATION /d M/S drea Will /e&Veh auxiliary leedasler flog An analysis was serformed b the licensee which demonstrated that a firer '
" M teJ iv m e ei th: tuH'faryf;;da:ter(Ar")pumpreer;aculdnotdefe4-th: Ouxi'ary feedweter 4ystem. A fire in say one of the pump-reem; wou!d ,
LT,pect -the A system Ply to the extent-thek aae W pump end-MW-f4e* to of /M J onesteamgeneratorpouldbedhablede e A0for'c rive TheTAFW pump rooms-nare highly segregated watertight rooms with 2 feet thick reinforced concrete walls and watertight doors that are maintained closed. !
Lubricating oil and cable insulation are the only combustibics present in the pump rooms. Leaking oil would be contained within the individual rooms or would>+4r* into the sump servicing the room. The combustible loading of g eeny one pump room is estimated to be less than 30,000 Btu /f t2 with a maximum fire severity of less than 30 minutes.
l -
~
l Train B r. der druen W wmo r n Enclosure 44 woold be c.on Rned (Mhd adec+ec u n crn 6hd aAvW meterdriven Brepump ouhide remthewouTraind' net the Trai n B gurnP ae.s asWa A smoke detettien system is installed aphaYh n thMfee Y5 au', ilia ry -^F feedwater pump rooms. The detection system would provide early warning of a fire, allowing the fire brigade adequate time to respond. A manual hose station, portable carbon diox1de extinguishers, and portable smoke removal equipment are available for use in the area.
The room construction coupled with a low quantity of combustible material, /
the presence of smoke detection systems, and the availability of equipment for use by the fire brigade substantiates the contention that a fire in oned' OLtk N pv9-eem ult! de mMned-to-the-eHeetet-roer. Such a fire would not prevent auxiliary feedwater flow to at least one steam generator.
Credit has been taken for the separation afforded by the wbject-pymp room boundaries. To ensure that the as-built configuration is maintained the sealed penetrations 11 be placed in the licensee's fire barrie surveillance program, forthis rkrn moOj'Aglen AFW A smoke detection system is installed throughout the area. An automatic sprinkler system is installed over the CCW pumps and in areas where cables are concentrated. The sprinkler system will be modified in order to previde direct unobstructed impingement on the CCW pumps. The combustible loading in the room is less than 35,000 Btu /ftr with a maximum fire severity of less than 30 minutes. The detection system in the room would provide early warning of a fire allowing the fire brigade adequate time to respond. A manual hose station, portable extinguishers, and portable smoke removal equipment are available for use in the area.
The CCW pumps are located on 21-feet centers. Heat detectors are providtd in the 5-kV CCW pump disconnect switch which alarms locally and in the control room. The 5 kV disconnect switch cabinets are provided with a total-flooding carbon dioxide system which is activated by the heat detectors.
The CCW pump cables are wrapped with two 1-inch layers of Knowool with the exception of the Train-A cables for the swing CCW pump which are wrapped with a $ dngle 1-inch layer. All traint cf CCW pump cables are covered by an auto,atic sprinkler system.
Cables for the Train-B service water inlet and discharge valves on the CCW heat exchangers are protected by the 1-inch layers of Kaoviool and covered by automatic suppression. Cables for the Train-A service water inlet and discharge valvcs on the CCW heat exchanger are not protected. Although neither Train-A or Train-B service water valves are provided with fire barriers, the nearest redundant valves are separated by a distance of approximately 10 feet. Intervening combustibles between redundant valves are minimal, consisting primarily of cable insulation.
The licensee's fire hazards analysis has shown that a postulated fire in rooms 2185, 2189, 2190, 2194, or 2241 would potentia.11y result in spurious operation of the main steam isolation valves, in the event that the main stent isolation valves f ail to isolate due to fire incuccd f ailures in the
_ _ _ _ _ __.m.________ _ _ - - - - - - - - . _ . _ _ . - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
- .- - ._~. - -, . - -- . _. . _ . - - . _ _ . . _ _ -
. 4 JUSTIFICATION FOR ADJUSTMFRT OF NRC SAFETY EVALUATION FOR APPENDIX R EKEMPTIONS TRANSMITTED BY NRC 1.ET17:R DATED DECEMBER 29, 1986 Exemption request 2-35 for fire area 2-006 analyred the Auxiliary Feedvater (AFV) pump rooms as separate zones within the fire area. Subsequent to the issuance of the requested exemptions Alabama Power Company performed a review of the exemption request to document the non-rated barriers which are required for Appendix R Separation to maintain these pump rooms as separate zones. Durin.t this reviev, it was identified that the room cooler for the Train A motor driven AFV(HDAFV) pump room vas located outside of the pump room. Thus, the exemption request was incorrect in its description of the components and the SER does not reflect the actuni plant condition. An evaluation of the as built condition grouped Zone 2 (vestibule area), Zone 3 (Train A HDAFV pump room) and Zone 5 (Turbine Driven AFV pump room) into one zone and demonstrated and that a fire outside Zone 4 (Train B HDAFV pump toom) vill leave Train B HDAFV flow to at least one steam generator, and a fire inside Zone 4 vill not affect AFV flov from the Train A HDa.V pump or the Turbine Driven AFV aump. Therefore, AFV flov to at least one steam generator vill be approved by the present configuration and vould be unaffected by a fire in the area. This is consistent with the NRC's conclusion for granting the exemption in this area and reflects the as built configuration existing during the NRC valkdovn.
- _ , _ . - .