ML18051A498
| ML18051A498 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/25/1983 |
| From: | Toner K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8308010338 | |
| Download: ML18051A498 (8) | |
Text
consumers Power company General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-0550 July 25, 1983 Dennis M Crutchfield, Chief Operating Reactor Branch No 5 Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR
- PALISADES PLANT - FIRE PROTECTION RULE - ALTERNATE SAFE SHUTDOWN CAPABILITY -
REQUEST FOR A SUPPLEMENT REPORT TO THE MAY 26, 1983 SAFETY EVALUATION REPORT The NRC staff has completed a review of the Palisades Plant alternate safe shutdown capability as documented in the Safety Evaluation Report (SER) dated May 26, 1983.
The purposes of this letter are as follows:
- a.
Provide Consumers Power Company's comments to the SER.
- b.
Submit exemption requests to certain requirements of 10 CFR 50, Appendix R, Section III.G.3 as they pertain to fixed fire suppression requirements.
(It is under-stood by Consumers Power Company that the "tolling provisions" of 10 CFR 50.48c(6) are no longer in effect.)
- c.
Request the NRC staff to issue a supplement SER to address items (a) and (b).
Consumers Power Company's comments to the SER are provided in Attachment 1.
Exemption requests to certain provisions of 10 CFR 50, Appendix R, Sec-tion III.G.3 are provided in Attachments 2 and 3.
The exemption requests pertain to fixed fire suppression requirements.
It is hereby requested that the NRC staff issue a supplement to the May 26, 1983 Fire Protection SER to address the supplemental information attached.
~cznt~U(_,,
-~erry f Toner Senior Licensing Engineer CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachments 8308010338 830725 PDR ADOCK 05000255 F
PDR OC0783-0003A-NL02
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- -.J.
ATTACHMENT 1 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET No 50-255 Comments on the NRC Staff's Safety Evaluation Report dated May 26, 1983, Entitled, "Safety Evaluation by the Office of Nuclear Reactor Regulation, Review in Accordance with Appendix R, Sections III.G and III.L, Consumers Power Company, Palisades Plant, Docket No 50-255."
July 1983 2 pages OC0783-0003B-NL02
ITEM 1:
CONSUMERS POWER COMPANY COMMENTS TO THE NRC STAFF'S FIRE PROTECTION RELATED SAFETY EVALUATION REPORT DATED MAY 26, 1983 Page 1 of 2 SER APPLICABLE SECTIONS:
1, 2.D, 4 COMMENTS:
It is stated in the SER that the NRC staff's review of the Palisades Plant alternate shutdown modifications was done in accordance with the requirements of 10 CFR 50, Appendix R, Sections III.G and III.L.
It is acceptable to refer to the provisions of Section III.L as providing guidance in the Staff's review.
It is incorrect to designate the provisions of Section III.L as requirements for the Palisades Plant.
10 CFR 50.48(b) states the following:
"Except for the requirements of Sections III.G, III.J, and III.O, the provisions of Appendix R to this part shall not be applicable to nuclear power plants licensed to operate prior to January 1, 1979, to the extent that fire protection features proposed or implemented by the licensee have been accepted by the NRC staff as satisfying the provision of Appendix A to Branch Technical Position BTP APCSB 9.5-1 reflected in staff fire protection safety evaluation reports issued prior to the effective date of this rule."
The NRC staff has previously accepted Consumers Power Company's fire protection features, as satisfying the provision of Appendix A to Branch Technical Position BTP 9.5-1, dated August 23, 1976.
This acceptance is documented in the NRC staff's safety evaluation reports issued prior to the effective date of 10 CFR 50.48 (References 1, 2, and 3).
Reference 3 acknowledges the fact that Consumers Power Company initiated alternate safe shutdown plant modifications prior to the effective date of 10 CFR 50.48.
Reference 3 states that the comple-tion dates for alternate safe shutdown modifications are "now governed by the Commission's new fire protection regulations, 10 CFR 50.48."
PROPOSED RESOLUTION:
Modify the appropriate SER sections to refer to the provisions of 10 CFR 50, Appendix R Section III.L as an NRC staff guideline rather than requirements for the Palisades Plant alternate safe shutdown modifications.
OC0783-0003C-NL02
ITEM 2:
Page 2 of 2 SER APPLICABLE SECTIONS:
4 COMMENTS:
Item 1 is a general comment to the SER regarding references to 10 CFR 50, Appendix R, Section III,L as a requirement.
This item addresses a specific statement in the SER regarding Section III.L.
The SER states that Consumers Power Company will "verify that the steam jet air ejector can be used to achieve cold shutdown within the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> required by Appendix R.
11 The 72-hour time frame to achieve cold shutdown is a specific provision of Section III.L.
For the same reason provided in Item 1, it is incorrect to refer to this 72-hour time frame as a requirement of Appendix R for the Palisades Plant.
The appropriate requirement for the Palisades Plant is stated in Subsection III.G(l).b, "Systems necessary to achieve and maintain cold shutdown from either the control room or emergency control station(s) can be repaired with 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />,"
(emphasis added).
PROPOSED RESOLUTION:
Modify SER Section 4 to refer to the 72-hour time frame to reach cold shutdown as an NRC staff guideline rather than a requirement for the Palisades Plant.
References
- 1. Letter, NRC to Consumers Power Company, Docket No 50-255, 9/1/78
- 2.
Letter, NRC to Consumers Power Company, Docket No 50-255, 3/19/80
- 3. Letter, NRC to Consumers Power Company, Docket No 50-255, 2/10/81 OC0783-0003C-NL02
OC0783-0003D-NL02 ATTACHMENT 2 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET No 50-255 EXEMPTION REQUEST July 1983 1 page
EXEMPTION REQUEST 10 CFR 50 Appendix R Section III.G.3 contains the requirement that a fire detection and a fixed fire suppression system be installed in fire areas, rooms or zones requiring alternative or dedicated shutdown capabilities.
Consumers Power Company has concluded that the requirement for a fixed fire suppression system for the Palisades Plant Engineered Safeguards Panel Room (a fire area, room or zone designated as requiring an alternative or dedicated shutdown capability) is unnecessary for the following reasons:
- a.
The room is surrounded by a 3-hour rated fire barrier.
All penetrations are sealed with 3-hour rated material and ventilation ducts have 3-hour rated fire dampers in them where they pass through walls or floors.
Ceiling height is approximately 10 feet with a total room volume of about 4200 cubic feet.
Access to all areas of the room is uninhibited.
- b.
The Palisades Plant alternate shutdown design provides adequate assurance that the required safety functions can be performed at the alternate shutdown control panel, C-150, independent of a fire in this room.
Panel C-150 provides a safe shutdown path independent of the Engineered Safeguard Panel Room.
- c.
The fire loading in this room is considered moderate in terms of fixed and transient combustibles.
The fire load consists of enclosed control panels and a moderate amount of cable tested for flame resistance in accordance with IPCEA Standard S-19-81.
There are no sources of ignition in the room.
Access to the room is through a locked and alarmed door.
The routine traffic of personnel through or into the room is very light.
If a fire starts in a panel, it would be contained within by the sheet metal walls.
A fire is not postulated to spread from the panels to the cables above or vice versa.
- d.
A fire detection system is provided within the room which provides early fire detection capability.
Portable fire extinguishers are located in the room and outside nearby.
A manual hose station is also readily available and within 40 feet of the room.
A fire brigade will respond upon receiving the alarm provided by the detection system.
Based on the reasons stated above, Consumers Power Company does not consider a fixed fire suppression system necessary for the Palisades Plant Engineered
.Safeguards Panel Room.
OC0783-0003E-NL02
OC0783-0003F-NL02 ATTACHMENT 3 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET No 50-255 EXEMPTION REQUEST July 1983 1 page
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EXEMPTION REQUEST 10 CFR 50 Appendix R Section 111.G.3 contains the requirement that a fire detection and a fixed fire suppression system be installed in fire areas, rooms or zones requiring alternative or dedicated shutdown capabilities.
Consumers Power Company has concluded that the requirement for a fixed fire suppression system for the Palisades Plant Corridor between the Charging Pump Room and Switchgear Room 1-C (a fire area, room or zone designated as requir-ing an alternative or dedicated shutdown capability) is unnecessary for the following reasons:
- a.
The corridor is about 85 feet long, having a width varying from 7 feet to 10 feet and having an approx-imate 12-foot-high ceiling.
Construction is re-inforced concrete and concrete block throughout.
Congestion is considered light to moderate.
- b.
The Palisades Plant alternate shutdown design provides adequate assurance that the required safety functions can be performed at the alternate shutdown panel, C-150, independent of a fire in the corridor.
Panel C-150 provides a safe shutdown path independent of the cables in the corridor.
- c.
The majority of the combustibles in the corridor consist of cable in trays located near the ceiling.
The quantity of cable is considered moderate.
The cable has been tested for flame resistance in accord-ance with IPCEA standard S-19-81.
There are no sources of ignition in or near the cable trays.
Transient combusti.bles are light for the majority of the time and moderate for several hours a day.
Transient combustibles consist primarily of anti-contamination clothing and maintenance materials.
These ~ombustibles are regularly removed~
These combustibles are located on the floor at least 6 feet below the cables.
Personnel traffic through the corridor is moderate.
Regular operator rounds are conducted in and around the corridor.
The corridor is easily accessible from several directions and the entire cable tray length is accessible for fire fighting from the floor.
- d.
Portable fire extinguishers are located in the corri-dor.
A manual hose station is located in the corri-dor.
A fire detection system is installed which will provide early warning of a fire.
A fire brigade will respond immediately upon alarm from the detection system or upon discovery of a fire.
Based on the reasons stated above, Consumers Power Company does not consider a fixed fire suppression system necessary for the Palisades Plant Corridor Between the Charging Pump Room and Switchgear Room 1-C.
OC0783-0003G-NL02