Text

Summarizes Recent self-audit Review Program Initiated to Evaluate & Resolve Differences Between Requirements of App R & Protective Measures Presently in Effect.Cpc 821206 Exemption Request Re Source Range Flux Monitor Withdrawn
	ML18051A864
Person / Time
Site:	Palisades
Issue date:	04/23/1984
From:	Vandewalle D; CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Crutchfield D; Office of Nuclear Reactor Regulation
References
	NUDOCS 8404250019
	Download: ML18051A864 (44)
	v • d • e

- ,,

consumers Power company General Offices: 1945 West Parnall RQad, Jackson, Ml 49201 * {517} 7$$-0550 April 23, 1984 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 - EXEMPTION REQUESTS AND MODIFIED COMMITMENTS Given the recent NRC findings of non-compliance with Appendix R at several nuclear power plants, Consumers Power Company initiated a self-audit program to evaluate and resolve, as necessary, differences from Appendix R require-ments. The charter of this self-audit program is described in Consumers Power Company's submittal dated January 18, 1984. The purposes of this submittal are to:

a. summarize the review process

b. describe differences from Appendix R requirements and subsequent resolution.

c. modify previous fire protection commitments to reflect acceptable alternatives preferred by Consumers Power Company.

REVIEW PROCESS The review process included the following steps:

a. Develop a comprehensive understanding of Appendix R to 10 CFR 50.

Our understanding of Appendix R requirements is illustrated by Attachment _l of our January 18, 1984 submittal.

b. Identify rooms, barriers and penetrations in the plant. This process is illustrated by Attachment 1, Figure 1. Figure 1 presents a hypothetical floor plan identifying rooms, barriers and penetra-tions.

8404250019 840423 PDR ADOCK 05000255 F PDR FP0484-0001B-NL02

.---~- ------~* - -

DMCrutchfield, Chief Palisades Plant

FIRE PROTECTION - EXEMPTION REQUESTS April 23, 1984 2

c. Define fire areas (per Generic Letter 83-33, October 19, 1983).

This process is illustrated by Attachment 1, Figure 2. Rooms which are not separated by adequate fire barriers are considered to be "connected." A fire area is defined to be the set of interconnected rooms.

d. Identify systems/trains/equipment necessary to perform each safety function described in Section III.L of Appendix R to 10 CFR SO.

(The safety functions are: reactivity control, inventory control, heat removal, and process monitoring.) This process is illustrated by Attachment 1, Figure 3. Figure 3 identifies a hypothetical functional group of equipment required to borate the primary coolant system. Each functional group of equipment belongs to a given "train."

e. Document the location and cable route for each piece of equipment considered in the review. This process is illustrated by Attachment 1, Figures 4A and 4B. Figure 4A is a hypothetical equipment location and cable route drawing. Figure 4B presents the Figure 4A information in tabular form.

f. Evaluate cable separation. This process is illustrated by Attach-ment 1, Figures S, SA and SB. Figure S demonstrates a flow chart for identifying potential common mode failures of redundant trains of equipment. Figures SA and SB illustrate how to determine if a train of equipment is potentially subject to fire damage.

DIFFERENCES FROM APPENDIX R The self-audit revealed differences existing between the protective measures prescribed by Appendix R and the protective measures available at Palisades Plant. Resolution was sought for each such difference. The methods used to resolve differences are:

a. Modify the plant to ensure strict compliance with Appendix R.

Submit schedule exemption request where justified.

b. Modify the plant to the extent necessary to ensure adequate protection is provided which meets the intent of Appendix R. Submit technical exemption request and, where justified, submit schedule exemption request.

c. Demonstrate that adequate protection is available which meets the intent of Appendix R. Submit technical exemption request.

Plant modifications which are a direct result of the self-audit are described in Attachment 8. The modifications are being implemented per the schedule provided in 10 CFR S0.48, therefore, no schedule exemption requests are currently necessary. Technical exemption requests are provided in Attachments 3 thru 7.

FP0484-0001B-NL02

DMCrutchfield, Chief 3 Palisades Plant FIRE PROTECTION - EXEMPTION REQUESTS April 23, 1984 PREVIOUS COMMITMENTS identifies previous fire protection commitments which have been modified to reflect acceptable alternatives preferred by Consumers Power Company.

CONCLUSION This submittal supplements the NRC Safety Evaluation Report dated May 26, 1983 and exemption requests submitted by Consumers Power Company letter dated July 25, 1983. The July 25, 1983 exemption requests address Appendix R Section III.G.3 requirements for detection and fixed fire suppression in the Engineered Safeguards Panel Room and the Corridor between the Charging Pump Room and Switchgear Room 1-C.

Consumers Power Company's exemption request, submitted December 6, 1982 is hereby withdrawn. The December 6, 1982 exemption request addressed the operator action necessary to connect the source range flux monitor at the alternate shutdown panel. Section E of NRC Safety Evaluation Report, dated May 26, 1983 states that this operator action is "compatible with the requirements of Appendix Rand, therefore, acceptable."

Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachments FP0484-0001B-NL02

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INDEX FOR ATTACHMENTS ATTACHMENT TITLE 1 APPENDIX R REVIEW PROCESS (FIGURES 1, 2, 3, 4A, 4B, 5, SA AND SB) 2 MODIFICATIONS TO PREVIOUS FIRE PROTECTION COMMITMENTS 3 EXEMPTION REQUEST - SECTION III.G.2 OF APPENDIX R TO 10 CFR 50 SERVICE WATER PUHP SEPARATION IN INTAKE STRUCTURE 4 EXEMPTION REQUEST - SECTION III.G.2 OF APPENDIX R TO 10 CFR 50 ENGINEERED SAFEGUARDS AREA 5 EXEMPTION REQUEST - SECTION III.G.2 OF APPENDIX R TO 10 CFR 50 RATED BARRIERS 6 EXEMPTION REQUEST - SECTION III.G.2 OF APPENDIX R TO 10 CFR 50 COMPONENT COOLING WATER ROON 7 EXEMPTION REQUEST - SECTION III.G.2 AND III.G.3 OF APPENDIX R TO 10 CFR 50 - CHARGING PUMPS P-SSB AND P-55C 8

SUMMARY

, PLANT MODIFICATIONS RESULTING FROM "APPENDIX R SELF-AUDIT" FP0484~0001L-NL02

I. J ATTACHMENT 1 Consumers Power Company Palisades Plant - Docket 50-255 APPENDIX R REVIEW PROCESS (FIGURES 1, 2, 3, 4A, 4B, 5, SA AND SB)

April 1984 8 Pages FP0484-0001C-NL02

CONSLJ.MERS POWER COM~NY

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CALL ROOMS IDENTIFIED FIRE ROOM AREA NUMBER CS>

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SYSTEM/TRAIN/EQUIPMENT IDENTIFICATION CHYPOTHEl !CAL EXAMPLE>

LEGEND EXAMPLE <HYPOTHET ICAU - - - ELECTRICAL CABLE OF CONCERN

--PIPINO SYSTEM A. IRA IN I. PLUS SUPPORT

EDUIPMENT SUBJEC::T TO MALOPERATION DUE TO ASSOCIATED CIRCUITS, HOT SHORTS, OPEN CIRCUITS, CIPI SHORTS TD GROUND.

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~-* -' CONSL91ERS POWER COM-NY FIGURE 5 EVALUATE SEPARATION OF TRAINS 1 AND 2 START COMPARE TRAIN ONE EQUIPMENT TO FIRE AREA A CSEE FIGURE 5A)

NO NEXT FIRE AREA YES COMPARE TRAIN TWO TO FIRE AREA A

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NO YES ENSURE ONE TRAIN FREE OF FIRE DAMAGE US ING 10 CFR 50.

APPENDIX R REQUIREMENTS

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TRAIN 1 LOCATION x x x CF IGURE 48> BORATION PUMP *1 TRAIN 1 LOCATION x x x CF IGURE 48>

RESULTS OF COMPARISON

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RESULTS OF COMPARISON

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lit f ATTACHMENT 2 Consumers Power Company Palisades Plant - Docket 50-255 MODIFICATIONS TO PREVIOUS FIRE PROTECTION COMMITMENTS April 1984 2 Pages

\

FP0484-0001C-NL02

J ATTACHMENT 2

e MODIFICATIONS TO PREVIOUS FIRE PROTECTION COMMITMENTS The following changes to previous fire protection commitments provide acceptable alternatives to the original commitments.

Item: 1 Submittal Date: May 19, 1981 (Refer to Attachment 1, Item S(c))

Original Commitment: In order to demonstrate that changes to safety systems will not degrade safety systems the connection of the charging pumps to their normal safety grade sources was to be assured by administrative control and by padlocks. This commitment was made in response to the following NRC concern:

"Demonstrate that changes to safety systems will not degrade safety systems. (e.g., new isolation switches and control switches should meet design criteria and standards in FSAR for electrical equipment in the system that the switch is to be installed; cabinets that the switches are to be mounted in should also meet the same criteria (FSAR) as other safety related cabinets and panels; to avoid inadvertent isolation from the control room, the isolation switches should be keylocked, or alarmed in the control room if in the "local" or "isolated" position; periodic checks should be made to verify switch is in the proper position for normal operation; and a single transfer switch or other new device should not be a source for a single failure to cause loss of redundant safety systems."

Revised Commitment: The connection of the charging pumps to their normal safety grade sources is assured by proper administrative control. A system checklist is performed to verify the position of the breakers prior to plant heatups (unless waived by the Operations Superintendent) and is controlled by a system operating procedure.

The equipment design prevents the connection of more than one pump to the alternate feed and more than one source of power to a charging pump. In addition, the use of padlocks is considered detrimental should the need arise to realign power sources and is inconsistent with the present plant practice of not locking breakers of safety related equipment.

FP0484-0001J-NL02

2 MODIFICATIONS TO PREVIOUS FIRE PROTECTION COMMITMENTS Item: 2 Submittal Date: March 31, 1971 (Page VII-51)

Original Commitment: Functional diversity is provided for Charging Pumps P-55A, B and C by the three High Pressure Safety Injection Pumps.

Modified Commitment: Adequate protection shall be provided in rooms 104, 104A, and 104B to ensure operability of Charging Pump P-55B or P-55C. The High Pressure Safety Injection Pumps are not essential for post-fire safe shutdown.

FP0484-0001J-NL02

ATTACHMENT 3 Consumers Power Company Palisades Plant - Docket 50-255 EXEMPTION REQUEST SECTION III.G.2 OF APPENDIX R TO 10 CFR 50 SERVICE WATER PUMP SEPARATION IN INTAKE STRUCTURE April 1984 3 Pages FP0484-0001C-NL02

ATTACHMENT 3 EXEMPTION REQUEST SERVICE WATER PUMP SEPARATION IN INTAKE STRUCTURE Equipment Under Consideration Service Water Pumps P-7A, P-7B, P-7C (P&ID M-213, Equipment Location Drawing M-11)

Diesel Driven Fire Pump P-41 (P&ID M-216 Sh.l, Equipment Location Drawing M-11)

Safety Function(s) Of Equipment The Service Water Pumps provide cooling water to the jacket of each diesel generator. The diesel generators are a required A-C power supply for hot shutdown equipment if offsite power is not available *. The diesel driven fire pump P-41 is an acceptable alternative to the service water pumps.

Exemption Request Section III.G.3 of Appendix R to 10 CFR 50 to the extent that the fire pump P-41 is required to be independent of the fire area containing the Service Water Pumps.

Fire Area Definition (Ref Dwgs C-42, C-43, and C-334)

The fire area consists of Room 136.

Necessary Plant Modifications Install radiant energy shield around two sides of diesel driven fire pump P-41 and diesel driver K-10. Controller C-137 is shielded by an existing non-safety related panel.

Implementation Schedule For Modifications Title 10 CFR 50.48, Section C.3. (Before Startup from current refueling outage which began August, 1983.)

Justification For Exemption Request a) The service water pumps and fire pumps are located in the intake structure on the 590' elevation of the plant. The structure is of reinforced concrete construction. The walls are 18" thick. Three of the walls are outside walls. The east wall provides a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months barrier to the turbine building. The penetration seals and the door in the east wall are rated at 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months . The roof is reinforced concrete construction. Fire exposure from the outside through the walls and roof is negligible.

The service water pumps are located 4 feet (center-to-center).

Conduit to each pump is from underground up through the concrete floor. The service water pumps are separated from the electric fire pump by approximately 9 feet and 20' from the nearest diesel driven fire pump.

FP0484-0001E-NL02

2 Exemption Request SERVICE WATER PUMP SEPERATION IN INTAKE STRUCTURE b) If offsite power is available the service water pumps are needed

only for cold shutdown. If offsite power is not available then a pump is needed for hot shutdown to cool the emergency diesel generators. Backup for the service water pumps is provided by any one of the three fire pumps through a cross-tie connection. The cross-tie connection is not in the immediate vicinity of the service water pumps and will be accessible in the event the cross-tie is required.

c) Fire loading in the screenhouse is light. Combustibles include minor amounts of cable, small quantities of high flash point lube oils and control panel wiring. Each service water pump and diesel fire pumps contain 7 gallons of high flash point lubricating oil.

The electric fire pump contains 1.75 gallons. The oil in all pumps and motors is contained internally and is not pressurized. The remaining equipment is piping, pumps, diesel engines and traveling screens.

There are no intervening combustibles between the service water pumps. A fire is not postulated to spread from the original area or equipment of involvement to any other area or equipment due to the lack of combustibles and the massive heat sink provided by the room construction and the piping in the room.

The diesel oil transfer pumps are located in a diked area in the southeast corner of the room. A fire there would be confined by the dike. The nearest service water pump is approximately 20 feet away from the dike.

Power and control cables to the service water pumps is from under-ground and up through the concrete floor. It is highly unlikely that any fire in the screenhouse would affect the pumps or their power and control cables.

d) The screenhouse has an automatic wetpipe sprinkler system installed.

Actuation of the sprinkler system is automatically annunciated (audible and visual) in the control room. Portable fire extinguish-ers are located in the room and immediately inside the turbine building. A fire hose station is located within 20 feet of the door in the turbine building and two fire hydrants with hose and nozzles are located outside.

Operators make frequent rounds into the room. A fire brigade will respond upon notification of a fire.

Due to the lack of combustibles and the automatic sprinkler system a fire is not postulated to spread beyond the original area of ignition.

The intensity of a fire at one service water pump would not be enough to involve either of the other two pumps.

FP0484-0001E-NL02

3 Exemption Request SERVICE WATER PUMP SEPERATION IN INTAKE STRUCTURE e) A fire in the screenhouse does not necessitate shutdown of the plant. This is true even if the fire involved one service water pump. If the plant were to be shut down, efforts would be made to shutdown in an orderly fashion so that offsite power is not lost. A fire in the screenhouse should not cause the loss of offsite power.

Thus, a fire involving all three service water pumps and the simultaneous loss of offsite power is not considered credible.

f) A radiant energy shield will be installed to shield fire pump P-41 and its diesel driver K-10 from the three service water pumps and the fire pump P-9B with its diesel driver K-5.

The shield wall is 18 ga galvanized sheet metal supported on structural steel spanning from floor to ceiling. The wall is 9' high, L-shaped, 5 1 and 12'. The pump controller C-137 is shielded by an existing non-safety related panel C-131.

FP0484-0001E-NL02

ATTACHMENT 4 Consumers Power Company Palisades Plant - Docket 50-255 EXEMPTION REQUEST SECTION III.G.2 OF APPENDIX R TO 10 CFR 50 ENGINEERED SAFEGUARDS AREA April 1984 2 Pages FP0484-0001C-NL02

L f ATTACHMENT 4 EXEMPTION REQUEST SECTION III.G.2 SEPARATION CRITERIA ENGINEERED SAFEGUARDS AREA Equipment Under Consideration Low Pressure Safety Injection Pumps P-67A and B.

Safety Function(s) Of Equipment Low Pressure Safety Injection Pumps P-67A and*B are required for heat removal after the primary coolant temperature reaches 325°F.

Exemption Request Section III.G.2 of Appendix R to 10 CFR 50 to the extent that redundant equipment is required to be separated by rated fire barriers.

Necessary Plant Modifications None Implementation Schedule For Modifications None Justification For Exemption Request The east and west rooms of the safeguards area contain redundant trains of cold shutdown equipment. The east and west areas of the safeguards room are separated by a wall having a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rating except for a substantial watertight door and several unrated pipe penetrations in the wall. Consumers Power Company has concluded that the watertight door and pipe penetrations will provide the protection necessary to maintain one train of cold shutdown equipment free from damage in the event of a fire on either side of the wall.

a) In previous reviews of the Plant the NRC has accepted this wall, the door and the pipe penetrations as equivalent to three hour separa-tion. (Reference attached to Safety Evaluation Report dated September 1, 1978, page 5-9, paragraph 5.9.1.)

b) The engineered safeguards area comprises the 570' elevation of the Palisades Plant. Construction is of poured reinforced concrete throughout. The rooms are separated from the remainder of the plant by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months construction. The wall between the redundant trains is 24-inches thick of poured reinforced concrete. The water tight door in this wall is of substantial construction (able to withstand a totally flooded room on one side) always closed and dogged. The pipe penetrations are sealed by 3/8" thick steel plate. The door FP0484-0001F-NL02

... *.J 2

Attachment 4 Exemption Request III.G.2. SEPARATION CRITERIA and pipe penetrations are considered to have a fire resistance in excess of any postulated fire severity.

c) The safeguards area is essential for the cold shutdown of the plant.

All redundant equipment in the rooms is separated by the wall described above. Only one room is required for the cold shutdown of the plant.

d) Combustible loading in either room is light consisting of pumps and associated motors, cable in conduit and trays, and minor amounts of high flash point lube oils. Transient combustibles are negligible and infrequent consisting of paper anti-contamination clothing. Any fire is postulated to last only a few minutes. A fire would generate light to moderate amounts of heat and smoke. Although equipment may be damaged on one side of the wall, a fire or it's effects is not postulated nor is it considered credible to affect equipment on the other side of the wall. Personnel traffic into the room is light and infrequent. The area is accessed through a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months door from the staircase.

e) A fire detection system is installed in the room providing quick notification of a fire. Portable fire extinguishers are available in the room and outside of the room. A hose station is available from the level above. The hose can reach all areas of the room. A fire brigade will respond immediately upon receiving the alarm in the control room.

FP0484-0001F-NL02

. *- .j ATTACHMENT 5 Consumers Power Company Palisades Plant - Docket 50-255 EXEMPTION REQUEST SECTION III.G.2 OF APPENDIX R TO 10 CFR 50 RATED BARRIERS April 1984 7 Pages FP0484-0001C-NL02

ATTACHMENT 5 EXEMPTION REQUEST RATED BARRIERS Equipment Under Consideration Fire Barriers listed in justification section.

Safety Function(s) Of Equipment Provide resistance to fire propagation.

Exemption Request Section III.G.2 of Appendix R to 10 CFR 50 to the extent that redundant equipment is required to be separated by rated fire barriers.

Necessary Plant Modifications None Implementation Schedule For Modifications None Justification For Exemption Request 10 CFR 50 Appendix R, Section III.G.2 contains the requirement that redundant trains of equipment needed for safe shutdown may be separated by a fire barrier having a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rating. The Fire Safety Analysis submitted on March 31, 1977 indicates that several walls in the plant are three hour walls.

Several doors in these walls are not labeled as to fire resistance. However, Consumers Power Company concludes that the doors installed provide sufficient resistance based on the fire loading on either side, In all but one case the unlabeled doors do not separate redundant equipment from each other. The doors provide separation from safe shutdown equipment to various other equipment and areas. In all but one case, safe shutdown equipment is separated from it's redundant equipment by barriers having a minimum of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire resistance.

Areas containing both redundant trains of equipment have been provided with an alternate shutdown method independent of the area.

The reasons the doors are not labeled are many. The reasons include: 1) labeled fire doors modified for security reason; 2) normal wear has caused the labels to fall off; 3) painters removing the labels to paint the doors; 4) the opening required a substantial watertight door; 5) fire-rated bullet resistant doors were not available when originally procured.

FP0484-0001G-NL02

2 Exemption Request RATED BARRIERS The following describes the individual doors that Consumers Power Company requests exemptions for:

a) The south wall of the control room contains a double door. These doors were originally 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months labeled doors. However, they were modified to provide the required security resistance. Recent tests at UL conducted by Wisconsin Public Service Corporation have shown that these doors withstood the UL lOB/NFPA 252 test well in excess of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , but not quite 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

The doors lead from the control room into a corridor that contains no combustibles. The corridor does not present an exposure hazard to the control room. The control room will be provided with an alternate shutdown method independent of the control room. Fire loading in the control room is considered minimal. With continuous manning and a smoke detection system installed, a fire will be detected and extinguished quickly. This door is constantly closed, locked and alarmed. Consumers Power Company concludes that these doors provide adequate fire resistance.

b) In the northwest corner of the control room is a single door. This door was originally a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months labeled door. However, it was modified to provide the required security resistance. Recent tests at UL conducted by Wisconsin Public Service Corporation have shown that this door passed the UL lOB/NFPA 252 test for 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire resistance.

This door leads from the control room into a small isolated corner of the turbine operating floor. The combustibles in or near this corner ate negligible. This corner is comprised of the control room wall, an outside wall and a concrete block stairwell. The fourth side opens to the turbine deck. A fire is not postulated to extend into this area due to the lack of combustibles.

Fire loading in the control room is considered minimal, with continuous manning and a smoke detection system installed a fire will be detected and extinguished quickly. This door is constantly closed, locked and alarmed. As previously mentioned, the door can provide 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months resistance. Consumers Power Company concludes that a rating label on the door is not necessary.

c) In the northwest corner of the cable spreading room (CSR) are a set of double doors. These doors are identical to those described in item a, above.

The doors lead from the CSR into an office/hallway area of the turbine building. The office/hallway area pose no hazards to the CSR because of the lack of combustibles. There is no safe shutdown equipment in the office/hallway.

The CSR will be provided with an alternate path of safe shutdown independent of the CSR.

FP0484-0001G-NL02

._, I J \JI 3

Attachment 5 Exemption Request RATED BARRIERS The doors will provide sufficient resistance from a fire in the off ice/hallway to the CSR. Fire loading in the CSR is considered moderate. The doors have been tested and have a rating in excess of two hours. The CSR is equipped with a smoke detection system and an automatic sprinkler system. A fire is not postulated to last long enough to breech these doors. The doors are constantly closed, locked and alarmed. Consumers Power Company concludes that these doors provide adequate fire resistance.

d) In the east wall of the North Cable Penetration Room is a single door. This door is identical to the one described in Item B above.

The door leads from the North Cable Penetration room into the Clean Resin Transfer and Storage Area. The wall it is installed in is considered to have a minimum 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire resistance. Fire loading on either side of the east wall is considered light to moderate. On the east side of the door and wall is the clean resin storage area.

Resins are stored in drums. Transient combustibles in this area consist of small amounts of Anti-C clothing. The fire loading in the cable penetration room consists of moderate amounts of cable. A fire detection system and an automatic sprinkler system is installed in the cable penetration room. The door is constantly closed, locked and alarmed. The North Cable Penetration Room is redundant to the completely separated Southwest Cable Penetration Room. As previously mentioned in Item b above, the door can provide 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire resistance. Consumers Power Company concludes that a rating label on the door is not necessary.

e) In the northeast corner of switchgear room lC is a single door leading to diesel generator room 1-1. The door is rated and labeled at 1-1/2 hours (Class B). The wall and any penetrations through it are rated at 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months . The door is locked, closed and alarmed. The fire loads in the switchgear room and diesel generator room are considered moderate and light, respectively. A fire in either area is not postulated to last longer than 1-1/2 hours.

An automatic sprinkler system and a smoke detection system are installed in the switchgear room. An automatic sprinkler system is installed in the diesel generator room.

An alternate and independent method of shutdown will be provided for the equipment in the switchgear room. The redundant diesel generator are separated from each other and from the switchgear room by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months construction.

Consumers Power Company concludes that this door provides adequate fire resistance.

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4 Attachment 5 Exemption Request RATED BARRIERS f) In the southeast corner of switchgear room lC is a set of double doors leading into a hallway. The doors are rated and labeled at 1-1/2 hours (Class B). The wall and any penetrations are rated at 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

The doors are iocked and closed. The fire load in the switchgear room and the hallway is considered moderate and a fire in either area is not postulated to last longer than 1-1/2 hours. Cables in the switchgear room also travel into the hallway. However, an alternate and independent method of shutdown will be provided for both the switchgear room and the hallway. Thus, a fire in either area will not affect safe shutdown.

An automatic sprinkler system and a smoke detection system is provided in the switchgear room. A smoke detection system is provided in the hallway.

Thus, Consumers Power Company concludes that these doors provide adequate fire resistance.

g) In the center of the west wall of diesel generator room 1-2 are two sets of back to back double doors. These doors lead into a hallway in the turbine building.

One set of doors are of substantial construction equivalent to a fire door. The other set of doors are watertight. The NRC has previously accepted watertight doors as equivalent to fire doors (Reference 2).

Both sets are constantly closed with one set locked and alarmed.

The wall and penetrations are rated at 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months . The fire loadings in the diesel generator room and the hallway are considered light.

An automatic sprinkler system is provided in the diesel generator room. Redundant equipment is not located in either area.

The combination of the watertight doors and the other doors provides in excess of 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months resistance.

Consumers Power Company concludes that these doors provide adequate fire resistance.

h) In the south wall of the auxiliary feedwater pump room are two back to back doors. One door is of substantial construction judged to have an equivalent 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rating. The other door is watertight.

Both doors are constantly closed with one door being locked and alarmed. Fire loading in the auxiliary feedwater pump room is minimal and light in the condensate pump room next door. Redundant safe shutdown equipment is not exposed by equipment in either room.

A smoke detection system is located in the auxiliary feedwater room.

The condensate pump room has an automatic sprinkler system.

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5 Attachment 5 Exemption Request RATED BARRIERS Watertight doors have been considered by the NRG as equivalent to 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated doors. The combination of the watertight door and the other are judged to provide in excess of 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months resistance.

Consumers Power Company concludes that these doors provide adequate fire resistance.

i) The battery rooms located in the cable spreading room are separated from each other and the cable spreading room by 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months construction but judged to be 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months . Construction of the walls consist of concrete block. Penetrations are rated at 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months . The door leading into the battery room is a labeled 1~ hour door. The door between the two battery rooms is a 1~ hour fire door on which the label has come off. The rooms have not changed substantially and the doors have not changed at all since acceptance of the fire safety analysis by the NRG.

A smoke detection system has been added and an airflow monitoring switch has been added. Fire loading is considered light. Smoke detection and automatic sprinklers are installed in the adjacent cable spreading room.

The 1-1/2 hour door and the unlabeled 1-1/2 hour door are judged to provide adequate fire resistance for any postulated fire.

Consumers Power Company concludes that these doors provide adequate fire resistance.

j) In the northeast corner of the component cooling water room (CCWR) are two sets of double doors located back to back. One set of doors are of substantial construction judged equivalent to a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months door. The other set is watertight. The doors lead from the CCWR into a hallway. The walls and penetration seals are rated at 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

Fire loading in the.CCWR is light and moderate in the hallway.

Redundant equipment is not exposed by equipment in either area.

Smoke detection systems are provided in the CCWR and the hallway.

Both sets of doors are normally closed. Watertight doors have been considered to be equivalent to 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months doors by the NRC. The combination of the watertight doors and the others provide in excess of 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months resistance.

Consumers Power Company concludes that these doors provide adequate fire resistance.

k) The door leading into the southwest cable penetration room from the turbine building is unlabeled. It was installed as a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months door but the label has come off.

FP0484-0001G-NL02

6 Exemption Request RATED BARRIERS Wall construction and penetration seals are rated at 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months . The room contains one channel of cables and the alternate shutdown panel. A redundant method of shutdown exists and is totally separated from this room.

Fire loading in the room and in the turbine building is considered moderate. However, it is considered light in the immediate vicinity of the door. The door is constantly closed, locked and alarmed.

The room is equipped with a smoke detection system and an automatic sprinkler system. Fire hoses and portable extinguishers are readily available outside the room.

A fire is not postulated to breech the door due to the lack of combustibles in the immediate vicinity of either side of the door and the moderate fire loadings elsewhere.

Consumers Power Company concludes that this door provides adequate fire resistance.

1) The engineered safeguards panel room is surrounded by walls having a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rating. Penetration seals are rated at 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months . However, the 3 doors into the room are rated at 1-1/2 hours. The labels on two of the doors have come off. However, they are the same doors that were originally installed and approved by the NRC. (Reference 1).

Fire loading in the room and in the surrounding area is considered moderate.

An alternate and independent method of safe shutdown will be provided for the room and the hallway outside. A smoke detection system is installed in the hallway and in the room.

Redundant equipment is not exposed on either side of the doors.

Consumers Power Company concludes that these doors provide adequate fire resistance.

m) In the south wall of the East Engineered Safeguards room is a substantial water tight door leading to the Post-Tensioning Tunnel of containment. The door is approximately 2' x 3~' in size. The wall the door is in is constructed of poured reinforced concrete providing in excess of 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire resistance. The Post-Tensioning Tunnel is completely devoid of combustibles, equipment or cable (a lighting circuit is installed). The tunnel is normally unoccupied.

No transient combustibles are present in the tunnel. The tunnel is totally cut off from containment by poured reinforced concrete.

There is no access from the tunnel into containment. In other words, the tunnel does not constitute a fire exposure to the East Engineered Safeguards Room.

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Attachment 5 Exemption Request RATED BARRIERS The fire loading in the East Engineered Safeguards Room is light, consisting of pumps, motors, some cable and minor amounts of the high flash point lube oil.

The water tight door is considered to have sufficient fire resistance to prevent a fire from propagating to the tunnel.

Watertight doors have been considered by the NRC as equivalent to 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire doors (Reference 2).

Consumers Power Company concludes that the watertight door provides sufficient fire resistance.

n. In the middle of the north wall of the Radwaste Addition are a set of watertight doors. The doors lead from a corridor in the Radwaste Addition to an electrical equipment room in the Service Building.

The wall (separating the Radwaste Addition and the Service Building) is made of poured reinforced concrete. The wall provides in excess of 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire ~esistance. There are no other openings in the wall.

There is no equipment necessary for safe shutdown on either side of the wall. A fire in the corridor of the radwaste addition would not release radioactivity.

Fire loading is lig~t in the corridor consisting of minor amounts of cable, metal enclosed switchgear and battery chargers. Neither side constitutes a hazard to the other side. The doors are constantly closed, chained and padlocked in the locked closed position, and electrically supervised. Watertight doors have been considered by the NRC to be equivalent to 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire doors (Reference 2).

Consumers Power Company concludes that the watertight doors provide sufficient fire resistance.

References

1. "Fire Protection Safety Evaluation Report" Palisades SER dated September 1, 1978. NRC acceptance of "Fire Doors, Hatches and Openings"

2. NRC Acceptance of watertight and bullet resistant doors as equivalent to fire doors Midland SER dated May 1982, NUREG-0973.

FP0484-0001G-NL02

ATTACHMENT 6 Consumers Power Company Palisades Plant - Docket 50-255 EXEMPTION REQUEST SECTION III.G.2 OF APPENDIX R TO 10 CFR 50 COMPONENT COOLING WATER ROOM April 1984 2 Pages FP0484-0001C-NL02

~ ,, v ATTACHMENT 6 EXEMPTION REQUEST COMPONENT COOLING WATER ROOM An unsealed penetration (barricaded opening) is provided between the Component Cooling Water Room and the adjacent Turbine Building to satisfy the require-ments of the high energy pipe break criteria. Consumers Power Company concludes that the existing barricaded opening mutually satisfies the high energy pipe break and fire protection criteria and requests an exemption from Section III.G.2 of Appendix R to consider this room as equivalent to a fire area surrounded by a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated barrier. The plant specific details described below provide an acceptable fire protection alternative to those prescribed by Section III.G.2 of Appendix R to 10 CFR 50. The details are as follows:

a) The room is oddly shaped with a 32 foot high ceiling. Total volume is approximately 47,120 cubic feet. Three of the four walls are 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire barriers. The floor and ceiling are 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire barriers.

The fourth wall was a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire barrier. This wall has an approximate 7' x 9' opening in it leading to the 590 elevation of the turbine building. The lower 4~' of the opening is covered by a steel blast panel.

The CCW pump room is uncongested containing light amounts of combustibles. The combustibles consist of cables and small amounts of high flash point lube oils. The CCW pumps are separated by 12 feet center-to-center. Other equipment of interest are located near the ceiling. The 590 elevation of the turbine building immediately around and near the opening is essentially void-of combustibles.

Construction is steel and concrete. No combustibles or other equipment pass through the opening.

b) The CCW pumps are needed only for cold shutdown. The equipment near the ceiling consist of valves and associated operators. This equipment may be used for safe shutdown. However, redundant equipment and valves are located in a separate fire area in the auxiliary building separated by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months construction.

c) Combustible loading in the CCW room is light consisting of the pumps, motors, associated cabling in conduit, minor amounts of other cable and negligible amounts of high flash point lube oils. Transient combustibles are negligible. Personnel traffic into and through the room is light and infrequent. The area is easily accessible for fire fighting. Combustibles near the opening are negligible.

Combustible loading in the turbine building in the area of the opening is negligible. Transient combustibles consist of negligible amounts of trash. Traffic inside the room is moderate and away from the opening.

Due to lack of combustibles on either side of the opening, fire is not postulated to pass through it. However, smoke will pass through but no damage is postulated.

FP0484-0001H-NL02

2 Exemption Request COMPONENT COOLING WATER ROOM d) A fire detection system is installed in the CCW room. A portable fire extinguisher is located in the room and others are located in the hallway outside of the room. A hose station is also available in the hallway. A fire brigade will respond immediately upon receiving the alarm in the control room. On the 590 elevation of the turbine building a fire will be discovered during regular operator rounds. A hose station and an extinguisher are available in the immediate vicinity of the opening.

Based on the reasons stated above, Consumers Power Company does not consider a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months barrier in the wall between CCW pump room and the 590 elevation of the turbine building to be necessary.

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I ... J ATTACHMENT 7 Consumers Power Company Palisades Plant - Docket 50-255 EXEMPTION REQUEST SECTION III.G.2 AND III.G.3 OF APPENDIX R TO 10 CFR 50 CHARGING PUMPS P-55B and P-55C April 1984 7 Pages FP0484-0001C-NL02

ATTACHMENT 7 EXEMPTION REQUEST CHARGING PUMPS P-55B AND P-55C Equipment Under Consideration Charging Pumps P-55B, P-55C.

Safety Function(s) Of Equipment The charging pumps are used for reactivity control and inventory control.

Exemption Request a) Section III.G.2 of Appendix R to 10 CFR 50 to the extent that the charging pumps and cables are required to be separated by twenty feet with no intervening combustibles.

b) Section III.G.3 of Appendix R to 10 CFR 50 to the extent that the alternate power is required to be in fire area independent of the power supplies to charging pumps P-55A and P-55B.

c) Section III.G.2 and III.G.3 of Appendix R to 10 CFR 50 to the extent that suppression and detection is required "in the area." (Generic Letter 83-33, October 19, 1983 defines "in the area" to be "through-out the area".)

Necessary Plant Modifications Reroute power feeds to charging pumps P-55C and P-55B. Seal penetrations into pipeway et al 602'0". Add Suppression to rooms 104, 104A and 104B.

Implementation Schedule For Modifications Power feed and seal penetration - Title 10 CFR 50.48 Section C.3 (before startup from the current refueling outage which began August 1983).

Suppression - Title 10 CFR 50.48 Section D.3 (before startup from the current refueling outage which began August 1983).

Justification For Exemption Request I. Room Under Consideration: Charging Pump Room (Charging Pump Room consists of rooms 104, 104A and 104B.)

a) The room is approximately 50' x 12' x 18' of reinforced concrete and concrete block. The room is essentially cutoff from the rest of the plant by these walls.

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2 Attachment 7 Exemption Request CHARGING PUMPS P-55B AND P-55C The reinforced concrete walls, floor and roof provide a barrier having a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire resistance. Entrance into the room is through openings in the north and south walls. Two 11 foot long corridors, running east and west along the rooms' north and south walls, open into the entrances. The corridors contain negligible amounts of combustibles. The corridor construction is also of reinforced concrete. A fire from the 590' elevation of the auxiliary building is not postulated to spread into the charging pump room due to the lack of combustibles in the corridors and the fire travel distance.

The room is uncongested as it contains only the charging pumps.

The pumps are separated by 15 feet with no intervening combustibles or fire hazards. In addition a poured concrete radiation wall is situated between each pump. This wall effectively acts as a fire shield wall.

A curb has been installed in the opening between the P-55A and P-55B pumps to contain any oil that might leak from one of the pumps. The curb will prevent an oil fire from spreading to the other pumps.

An oil fire is considered highly unlikely due to the small amounts of oil (23~ gallons in P-55A, 5~ gallons each in P-55B and C) and no sources of ignition, and the oil is totally enclosed in the pumps, from spreading to the other pumps. The access around the shield walls does not provide a direct line of sight path between the pumps.

b) Combustible loading is negligible consisting of only the pumps, motors, associated cabling in conduit and minor amounts of high flash point lube oils. Transient combustibles are negligible.

Personnel traffic into and through the room is light and infrequent.

The area is easily and readily available for fire fighting.

c) A fire detection system is installed in the room. An automatic sprinkler system is being installed in the room. Portable fire extinguishers are available immediately outside of the room and in the surrounding areas. A fire hose station is available in the hallway outside of the room. A fire brigade will respond immediately upon receiving the alarm in the control room.

d) The power feeds for pumps P-SSB and C are being rerouted so that they will be separated from each other by a wall within the charging pump room. The power feed for P-55B pump will enter the P-55B cubicle directly from the hallway. The power feed for P-55C pump will enter the C cubicle directly from the hallway. Within the pump room the power feeds will be separated by the shield wall.

e) An alternate power feed for pumps P-55B and P-55C is routed in the 602' elevation pipeway until it enters the charging pump room. The alternate is run entirely in conduit. The alternate feed enters the FP0484-0001I-NL02

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Attachment 7 Exemption Request CHARGING PUMPS P-55B AND P-55C P-55B cubicle and immediately crosses to the P-55C cubicle. A manual switch box is located in the P-55C cubicle. The switch transfers the alternate power feed to either Pump P-55B or Pump P-55C.

The 602' elevation pipeway is entirely devoid of combustibles.

f) Consumers Power Company believes that with the present cable routing and the modifications that are being made, one charging pump will always be available in the event of a fire anywhere on the 590' elevation.

Please refer to the attached drawing, chart, and explanations.

There are several unprotected openings from the 590' elevation to the 602' elevation pipeway. However, it is not considered credible for a fire to spread from 590' corridor to 602' pipeway. The paths from the 590' corridor to the 602' pipeway are winding ones. The fire must start in the corridor, travel through a door or doors, round corners and then travel up to the 602' elevation. Once the fire leaves the corridor it will run out of combustibles. When it reaches the opening to the pipeway there will be no combustibles.

The pipeway is entirely devoid of combustibles so the fire cannot spread into it. Some heat and smoke may enter the pipeway but the volume and massive heat sink of the pipeway will not allow damage to the alternate power feed.

g) The charging pump room was evaluated and found acceptable by the NRC for access, egress and fire protection for the room and adjacent hallway. Reference Palisades SER dated September 8, 1978, Section 4.12 and 5.8.

h) The HVAC ducts in the charging pump room/corridor are constructed of heavy gauge steel. The ducts are used for return air only. The ducts pull air from the charging pump room and exhaust it out of the auxiliary building.

Fire dampers will not be placed in these ducts where they pass through the walls because of minimal fire loading, and the automatic sprinklers will prevent any fire from damaging the duct work and because the ducts are exhaust only fire dampers will hinder the removal of smoke.

II. Rooms Under Consideration: Refer to table and figure which follow.

Justification: Refer to table and appropriate explanations.

FP0484-0001I-NL02

i PALISADES Charging Pumps Fire and Alternate Methods of Power Feed Refer to attached drawing and explanations Fire Location Probable Fire Damage Available Charging Pump(s) Explanation

1. Power feeds for A, B and C charging Alternate power feed to B and C pumps 1.

pumps

2. Power feed for A and B charging pumps C power .feed 2.

Alternate power feed

3. Power feeds for A, B and C charging Alternate power feed to B and C pumps 3.

pumps

4. Power feed for C charging pump A and B power feed 4.

Alternate power feed

5. A pump and power feed B and C pumps and power feeds 5.

Alternate power feed

6. A power feed, B pump, Alternate C pump and power feed 6.

power feed

7. A power feed, C pump, Alternate B pump and power feed 7.

power feed

8. A, B and C power feeds Alternate power feed 8.

Cable B and C pumps Spreading Room FP0484-0001I-NL02

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Explanations

1. A fire in the 590' corridor outside the lC switchgear room may damage the power feeds to charging pumps P-55A and P-55B. After a period of time the fire may breach the unrated, but substantial, doors into the spent fuel pool equipment room. This is considered unlikely because the combustibles in the corridor are above the level of the door. Other penetrations from the room to the corridor have been sealed. If the fire does extend into the room, the C pump power feed is assumed to be damaged.

This leaves the alternate power feed to pumps P-55B and P-55C. The alternate feed is run in the 602' pipeway in conduit. It exits the pipeway and enters the 590' radwaste exhaust fan room. From there it enters the component cooling water pump room (CCW).

The doors from the CCW pump room to the corridor consist of two sets of back-to-back, double doors. One set is watertight and always closed.

The other set is of substantial steel construction. A fire is not postulated to breach these doors. The entrance to the radwaste exhaust fan room is an open walkway from the corridor. The walkway is free of combustibles and of concrete construction.

A fire is not postulated to spread from the hallway into the walkway due to the lack of combustibles and distance. A fire in front of the lC switchgear room would have to travel approximately 35' to the walkway and then another 30' without combustibles to the alternate power feed conduit. Smoke will enter the walkway as will heat. The alternate feed is in conduit and it is not considered credible to be damaged by such a fire.

The corridor is equipped with smoke detectors that alarm in the control room. A five-man fire brigade will respond. Fire extinguishers and hose stations are available to the area.

2. A fire in the 590' corridor outside the decontamination room and the walkway to the radwaste exhaust fan room may damage the power feeds to charging pumps P-55A and P-55B. The power feed to the C charging pump and the alternate power feed would not be damaged.

The alternate power feed would not be damaged for reasons found in Explanation 1.

The C pump power feed would not be damaged either. The fire would have to travel approximately 35' and enter the spent fuel pool equipment room.

This is considered unlikely because the combustibles are above the level of the door. The door is a substantial steel door.

Another path from the fire to the P-55C power feed is through the deconta-mination room. This is not considered credible. The doors are substantial steel doors and always closed. The amount of combustibles in the room are not great enough to spread a fire across the room and through the second set of doors. The fire would go out in the decontam-ination room.

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Attachment 7

. Exemption Request CHARGING PUMPS P-55B AND P-55C

3. A fire in the 590' corridor outside the south entrance to the charging pump room may damage the power feeds to the P-55A, P-55B and P-55C charging pumps. The fire cannot spread into the charging pump room because there are no combustibles in the entrance corridor. The fire cannot spread north along the corridor because there are no combustibles.

The fire can spread east down the corridor which may cause damage explained in 1 and 2 above.

The alternate power feed is separated from the corridor and a fire cannot extend into the pipeway. An operator can enter the charging pump room using the north entrance. Once inside, he can switch control to the alternate power feed. The operator would wear self-contained breathing apparatus.

4. A fire anywhere in this corridor would only damage the P-55C pump power feed. In situ combustibles are negligible. This means that the fire must be fed by transient combustibles. Thus, the fire would be confined to the area of the combustibles. The fire is not postulated to spread beyond the area of involvement.

5. A fire in the P-55A charging pump cubicle would damage only the P-55A pump. The detection system will alarm in the control room. The auto-matic sprinkler will contain or extinguish the fire. The shield wall will prevent damage to the P-55B pump. The fire will not spread into the corridor due to the lack of combustibles along the path.

6. A fire in the P-55B charging pump cubicle would damage the P-55B pump, the P-55A pump power feed and the alternate power feed. The detection system will alarm in the control room. The automatic sprinkler system will contain or extinguish the fire. The shield wall will prevent damage to the P-55C pump *. The low amount of combustibles will limit the size of the fire.

7. A fire in the P-55C charging pump cubicle would damage the P-55C pump, the P-55A pump power feed and the alternate power feed. The detection system will alarm in the control room. The automatic sprinkler system will contain or extinguish the fire. The shield wall will prevent damage to the P-55B pump. The low amount of combustibles will limit the size of the fire.

8. A fire in the cable spreading room will damage the power feeds to the P-55A, B and C charging pumps. However, the alternate feed is totally separate and cutoff from the cable spreading room by minimum three-hour construction.

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It-' - :J ATTACHMENT 8 Consumers Power Company Palisades Plant - Docket 50-255

SUMMARY

, PLANT MODIFICATIONS RESULTING FROM "APPENDIX R SELF-AUDIT" April 1984 1 Page FP0484-0001C-NL02

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ATTACHMENT 8 PLANT MODIFICATIONS RESULTING FROM "APPENDIX R SELF-AUDIT"

1. Cover with three-hour fire rated material the control circuits for CV0736A & CV0737A as they pass through the CCW room.