ML18051B007
| ML18051B007 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/20/1984 |
| From: | Vandewalle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| GL-83-33, NUDOCS 8407270092 | |
| Download: ML18051B007 (11) | |
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- 9 consumers Power company General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-0550 July 20, 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 - REVISION 2 The NRC Staff advised Consumers Power Company that an exemption request is necessary to address cable separation inside containment.
This was brought to our attention July 18, 1984 during telephone conversations concerning excessive heating of certain cables inside containment (described more fully in NRC Confirmatory Action Letter dated July 13, 1984).
The purposes of this submittal are as follows:
- a. Provide the necessary exemption request
- b. Advise NRC of incorrect statements in Confirmatory Action letter dated July 13, 1984.
(Consumers Power Company actions are correct as shown.
However, certain statements providing background information are inaccurate.)
Exemption Request The exemption request supplements our submittal of July 16, 1984 and NRC Safety Evaluation Report dated May 26, 1983.
A complete index of fire protection exemption requests is provided with this submittal.
Consistent with the attached index, the exemption request provided with this submittal is labeled as Attachment 15. 5 addresses cable separation inside containment.
Adequate cable separation is provided by fire stops in certain cable trays.
The use of fire stops and the fire stop design was previously approved by NRC on March 11, 1980 as part of the Fire Hazards Analysis review prior to the issuance of Appendix R to 10 CFR 50.
Prior to this submittal, Consumers Power Company considered the fire stops to be adequately approved by the NRC considering provisions of Generic Letter 83-33 dated October 19, 1983.
NRC Staff advised that Generic Letter 83-33 provisions concerning "prior approval" are for OC0784-0006-NL02
DMCrutchfield, Chief Palisades Plant FIRE PROTECTION EXEMPTION REQUESTS -
REV 2 July 20, 1984 concerning "prior approval" are for fire area boundaries only and not applicable to fire stops.
Confirmatory Action Letter 2
Confirmatory Action Letter dated July 13, 1984 refers to a reportable event which occured on July 3, 1984.
Cable tray section identified as CP250 installed at elevation 590' inside the containment contained several safety-related cables including cables to the pressurizer heaters which were observed to have been degraded (damaged insulation) by excessivley high temperatures.
The following statements from the letter are incorrect:
- a. "The excessive heat was apparently confined to the area where a one hour rated fire barrier (OHRFB) was installed in 1979 to meet the 10 CFR 50 Appendix R requirements."
The fire barrier is a fire stop. It's purpose is to prevent a fire from propagating along a cable tray.
The fire stop is not rated at one hour.
The fire stop is not rated.
It w~ll simply stop a fire from propagating along the tray.
The fire stop was not installed to meet Appendix R requirements.
The fire stop was installed following our Fire Hazards Analysis and prior to issuance of Appendix R.
- b. "Inspect other cable trays inside containment wrapped with the one hour fire barrier, and notify this office if additional damage is identified."
As previously stated, fire stops at Palisades Plant are not rated barriers. A description of the fire barriers used inside containment is provided in the attached exemption request.
CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachments OC0784-0006-NL02
NRC APPROVAL ATTACHMENT STATUS 1
N/A lA N/A lB N/A lC N/A 2
N/A 3
OPEN 4
OPEN 5
OPEN Appendix A N/A 6
OPEN 7
OPEN FP0484-0001L-NL02 NEW INFORMATION THIS SUBMITTAL (YES/NO)
NO N/A NO NO NO NO NO NO NO NO NO INDEX FOR ATTACHMENTS July 20, 1984 APPENDIX R REVIEW PROCESS TITLE (Original Submittal April 23, 1984 - Revision 1 July 16, 1984)
ESSENTIAL EQUIPMENT FOR SAFE SHUTDOWN POST-FIRE (To be provided by August 10, 1984 - Attachment lA will provide a concise summary of essential equipment for safe shutdown)
FIRE AREA IDENTIFICATION (Original Submittal July 16, 1984)
EMERGENCY LIGHTING (Original Submittal, July 16, 1984)
MODIFICATIONS TO PREVIOUS FIRE PROTECTION COMMITMENTS (Original Submittal April 23, 1984 - Revision 1 July 16, 1984)
EXEMPTION REQUEST - SECTION III. G. 2 OF APPENDIX R TO 10 CFR 50 SERVICE WATER PUMP SEPARATION IN INTAKE STRUCTURE (Original Submittal April 23, 1984 - Revision 1 July 16, 1984)
EXEMPTION REQUEST - SECTION III.G.2 OF APPENDIX R TO 10 CFR 50 ENGINEERED SAFEGUARDS AREA (Original Submittal April 23, 1984 - Revision 1 July 16, 1984)
EXEMPTION REQUEST - SECTION III. G. 2 OF APPENDIX R TO 10 CFR 50 RATED BARRIERS (Original Submittal April 23, 1984 - Revision 1 July 16, 1984)
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TEST REPORTS WHICH SUBSTANTIATE ATTACHMENT 5 -
ITEMS a,b,c and d (Original Submittal July 16, 1984)
EXEMPTION REQUEST - SECTION III.G.2 OF APPENDIX R TO 10 CFR 50 COMPONENT COOLING WATER ROOM (Original Submittal April 23, 1984 - Revision 1 July 16, 1984)
EXEMPTION REQUEST - SECTION III.G.2 AND III.G.3 OF APPENDIX R TO 10 CFR 50 -
CHARGING PUMPS P-55B AND P-55C (Original Submittal April 23, 1984 - Revision 1 July 16, 1984)
- l
NRC APPROVAL ATTACHMENT STATUS 8
OPEN 9
OPEN 10 11 12 13 14 15 OPEN Approved 2/8/83 Withdrawn 4/23/84 N/A OPEN OPEN FP0484-0001L-NL02 NEW INFORMATION THIS SUBMITTAL YES/NO NO NO NO NO NO N/A NO YES INDEX FOR ATTACHMENTS July 20, 1984 TITLE
SUMMARY
, PLANT MODIFICATIONS RESULTING FROM "APPENDIX R SELF-AUDIT" (Original Submittal April 23, 1984 - Revision 1 July 16, 1984)
SECTION III.G.3 OF APPENDIX R TO 10 CFR 50 ENGINEERED SAFEGUARDS PANEL ROOM (Original Submittal July 25, 1983 - Revision 1 July 16, 1984)
EXEMPTION REQUEST - SECTION III.G.3 OF APPENDIX R TO 10 CFR 50 CORRIDOR BETWEEN CHARGING PUMP ROOM AND SWITCHGEAR ROOM lC (Original Submittal July 25, 1983 - Revision 1 July 16, 1984)
EXEMPTION REQUEST - SECTION III.G.3 OF APPENDIX R TO 10 CFR 50 CONTROL ROOM (Original Submittal July 1, 1982 - Revision 1 July 16, 1984)
SECTION III.G.l.a OF APPENDIX R TO 10 CFR 50 REPAIR PROCEDURE HOT SHUTDOWN INSTRUMENTATION (Original Submittal December 6, 1982 - Revision 1 July 16, 1984)
EXEMPTION REQUEST - SECTION III.L.4 OF APPENDIX R TO 10 CFR 50 LOCAL TENDING OF EMERGENCY DIESEL GENERATORS (To be provided by August 10, 1984) 3 will provide an exemption request from Section III.L.4 of Appendix R to 10 CFR to the extent that personnel must be available on-site at all times to implement procedures concerning local tending of a diesel generator.
In accordance with 10 CFR 50.48c(4), Attachment 13 must be resolved prior to startup from the next appropirate outage (60 day planned, 120 day unplanned, or refueling).
EXEMPTION REQUEST - SECTION III.G.2 OF APPENDIX R TO 10 CFR 50 INSTRUMENT SEPARATION INSIDE CONTAINMENT (Original Submittal.July 16, 1984)
EXEMPTION REQUEST - SECTION III.G.2 OF APPENDIX R TO 10 CFR 50 CABLE SEPARATION INSIDE CONTAIMENT (Original Submittal July 20, 1984)
J
FP0784-0001-NL02 ATTACHMENT 15 Consumers Power Company Palisades Plant - Docket 50-255 EXEMPTION REQUEST - SECTION III.G.2 OF APPENDIX R TO 10CFRSO CABLE SEPARATION INSIDE OF CONTAINMENT Original Submittal July 20, 1984 7 Pages
ATTACHMENT 15 EXEMPTION REQUEST - SECTION III.G.2 OF APPENDIX R TO 10CFR50 CABLE SEPARATION INSIDE OF CONTAINMENT Approval Status NRC review in progress.
Equipment Under Consideration Cables carrying signals for the following instruments:
PCS hot leg tempera-ture, PCS cold leg temperature, pressurizer pressure, pressurizer level, steam generator pressure, steam generator level, source range neutron flux.
Safety Function(s) of Equipment Process monitoring.
Exemption Request III.G.2.d of Appendix R to 10CFR50 to the extent that redundant cables are required to be separated with no intervening combustibles.
Necessary Plant Modification None Implementation Schedule for Modification None Justification for Exemption Request A.
Left and right channel cable trays, containing redundant instrumentation circuitry, inside of containment are routed such that they enter contain-ment in separate penetration areas and then pass through containment with at least 35 feet between them (refer to Figures 3A and 3B).
At one location within containment where the redundant trays are at least 20 feet apart (35 feet), a cable tray containing intervening combustibles (i.e. cables) connects two redundant sets of trays.
To prevent a fire from propagating from one channel to another via* these intervening combustibles, a fire stop has been installed on the interven-ing trays.
Two fire stop designs are used at the Palisades Plant.
The fire stop designs are shown in Figures 1 and 2.
The fire stop locations are shown in Figures 3A and 3B.
One fire stop consists of two blankets of 1~-inch Kaowool wrapped around a 4-foot section of tray (Refer to Figure 1).
Kaowool is packed tightly around the cables.
The Kaowool is banded to hold it in place.
Each tray in the stack is covered in this way.
The trays in the stack are then boxed by Marinite board to prevent pieces of the Kaowool from falling to the floor.
This arrangement has been accepted by NRC letter dated March 11, 1980.
FP0784-0001A-NL02
ATTACHMENT 15
. I EXEMPTION REQUEST FIRE PR TECTION CABLE SEPARATION INSIDE OF CONTAINMENT July 20, 1984 2
The other fire stop consists of a damming material and 9" of fire resistant silicone foam (refer to Figure 2).
The foam is in and around the cables and filled to the depth of the tray.
This in turn is covered by a noncombustible cover for the length of 3 feet centered on the middle of the foam.
All trays in the stack are covered in this way.
This arrangement is approved by American Nuclear Insurers (ANI).
B.
All transient combustibles are removed from containment before start up.
Strict administrative controls limit transient combustibles brought in during operation.
Normally, there is no need for combustibles to be brought in.
There are no sources of ignition in the area.
Smoking is strictly prohibited in containment.
C.
There are no sources of ignition that could ignite the cables.
Thus, a fire is highly unlikely.
D.
Smoke detectors have been installed in areas of cable concentration.
Detector location is shown in Figures 3A and 3B.
Alarms are annunicated in the control room.
Hose reels and portable extinguishers are available inside containment.
Consumers Power Company concludes that the existing cable separation is adequate.
FP0784-0001A-NL02
CABLE TAAY (LADDER TYPE) FIRE STOP 4'- o*
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