Text

Provides Addl Info Re Compliance w/10CFR50.48 & Rev 5 to 10CFR50,App R Re Fire Protection. App R Review Process, Revised to Address Understanding of Allowable Manual Operator Actions in Fire Area
	ML18051B132
Person / Time
Site:	Palisades
Issue date:	12/28/1984
From:	Johnson B; CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	; Office of Nuclear Reactor Regulation
References
	NUDOCS 8501020338
	Download: ML18051B132 (22)
	v • d • e

consumers Power company General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * {517) 788-0550 December 28, 1984

Director, Nuclear Reactor Regulation US Nuclear Regulatory Connnission Washington, DC 20SSS DOCKET S0-2SS - LICENSE DPR PALISADES PLANT - FIRE PROTECTION - COMPLIANCE - 10 CFR S0.48 AND APPENDIX R TO 10 CFR SO - REVISION S Consumers Power Company and NRC staff representatives participated in a conference call October S, 1984, concerning our exemption request for instrument separation inside containment (Attachment 14, July 16 1984 submittal). The purpose of this submittal is to provide supplementary information requested by the NRC Staff. In addition, revisions have been made to fire-protection-related information as follows:

Attachment 1, "Appendix R Review Process" is revised to address Consumers Power Company's understanding of allowable manual operator actions in the fire area where the fire started. A detailed description of manual*

operator actions which may be needed after a fire will be submitted in a subsequent letter.

Appendix A of Attachment 1, "Illustrations, Appendix R Review Process" is hereby submitted as an Appendix to Attachment 1. (Formally, this informa-

. tion was included in Attachment 1.)

Attachment 14, "Exemption Request - Section III. G. 2 of Appendix R to 10 CFR SO, Instrument Separation Inside Containment is revised to provide supplementary information requested by NRC Staff.

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Brian D Johnson ,- B50i02033Ef8.lff22B \*I*'I Staff Licensing Engineer 1 PDR ADOCK 05000255 I'

\ F PDR. lJ CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades OC1184-0002-NL02

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consume11 Power company General Offices: 1945 West Pernell Road, Jackson, Ml 49201

1517) 788-0550 December 28, 1984 Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - FIRE PROTECTION - COMPLIANCE - 10 CFR 50.48 AND APPENDIX R TO 10 CFR 50 - REVISION 5 Consumers Power Company and NRC staff representatives participated in a conference call October 5, 1984, concerning our exemption request for instrument separation inside containment (Attachment 14, July 16 1984 submittal). The pµrpose of this submittal is to provide supplementary information .requested by th~ NRC Staff. In addition, revisions have been made to fire-protection-related information as follows:

Attachment 1, "Appendix R Review Process" is revised to address Consumers Power Company's understanding of allowable manual operator actions in the fire area where the fire started. A detailed description of manual operator actions which may be needed after a fire will be submitted in a subsequent letter.

Appendix A of Attachment 1, "Illustrations, Appendix R Review Process" is hereby submitted as an Appendix to Attachment 1. (Formally, this informa-tion was included in Attachnient 1.)

Attachment 14, "Exemption Request - Section III.G.2 of Appendix R to 10 CFR 50., Instrument Separation Inside Containment" is revised to provide supplementary information requested by NRC Staff.

Brian D Johnson (signed)

Brian D Johnson Staff Licensing Engineer CC Administrator, Region III, *USNRC NRC Resident Inspector - Palisades OC1184-0002-NL02

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Director, NRR Palisades Plant FIRE PROTECTION REV 5

2 December 28, 1984 Attachments OC1184-0002-NL02

FIRE PROTECTION - EXEMPTION REQUESTS AND MODIFIED COMMITMENTS - REVISION 5 INDEX FOR ATTACHMENTS December 28, 1984 NRC NEW INFORMATION APPROVAL THIS SUBMITTAL ATTACHMENT STATUS (YES/NO) TITLE 1 N/A YES APPENDIX R REVIEW PROCESS (Original Submittal April 23, 1984 - Rev 1 July 16, 1984 -

Rev 2 August 10, 1984 Rev 3, December 28, 1984)

Appendix A N/A YES ILLUSTRATIONS, APPENDIX R REVIEW PROCESS of Attach I (Original Submittal December 28, I984) 1 IA OPEN Nb ESSENTIAL EQUIPMENT FOR SAFE SHUTDOWN POST-FIRE (Original Submittal August 10, I984) lB N/A NO FIRE AREA IDENTIFICATION, AUTOMATIC FIRE SUPPRESSION COVERAGE, AND FIRE DETECTOR COVERAGE (Original Submittal July 16, I984 - Rev 1 August IO, I984)

IC N/A NO EMERGENCY LIGHTING (Origin~! Submittal, July I6, I984) 2 N/A NO MODIFICATIONS TO PREVIOUS FIRE PROTECTION COMMITMENTS (Original Submittal April 23, 1984 - Revision I July 16, 1984 Rev 2 August 10, 1984) 3 OPEN NO EXEMPTION REQUEST - SECTION III.G.2 OF APPENDIX R TO IO CFR 50 SERVICE WATER PUMP SEPARATION IN INTAKE STRUCTURE (Original Submittal April 23, I984 - Revision I July I6, I984) 4 OPEN NO EXEMPTION REQUEST - SECTION III.G.2 OF APPENDIX R TO IO CFR 50 ENGINEERED SAFEGUARDS AREA (Original Submittal April 23, 1984 - Revision 1 July I6, 1984) 5 OPEN NO EXEMPTION REQUEST ~ SECTION III.G.2 OF APPENDIX R TO 10 CFR 50 RATED BARRIERS (Original Submittal April 23, 1984 - Revision I July I6, I984)

Appendix A N/A NO TEST REPORTS WHICH SUBSTANTIATE ATTACHMENT 5 - ITEMS a,b,c and d Of Attach 5 (Orig1-nal Submittal July I6, I 984)

I 1

FIRE PROTECTION - EXEMPTION REQUESTS AND MODIFIED COMMITMENTS - REVISION 5 INDEX FOR ATTACHMENTS December 28, 1984 NRC NEW INFORMATION APPROVAL THIS SUBMITTAL ATTACHMENT STATUS YES/NO TITLE 6 OPEN NO 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) 7 OPEN NO 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) 8 OPEN NO

SUMMARY

, PLANT MODIFICATIONS RESULTING FROM "APPENDIX R SELF-AUDIT" (Original Submittal April 23, 1984 - Revision 1 July 16, 1984) 9 OPEN NO EXEMPTION REQUEST - 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) 10 OPEN NO 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) 11 Approved NO EXEMPTION REQUEST - SECTION III.G.3 OF APPENDIX R TO 2/8/83 10 CFR 50 CONTROL ROOM (Original Submittal July 1, 1982 - Revision 1 July 16, 1984) 12 Withdrawn NO EXEMPTION REQUEST - SECTION III.G.l.a OF APPENDIX R TO 4/23/84 10 CFR 50 REPAIR PROCEDURE HOT SHUTDOWN INSTRUMENTATION (Original Submittal December 6, 1982 - Revision 1 July 16, 1984) 13 OPEN NO EXEMPTION REQUEST - SECTION III.L.4 OF APPENDIX R TO 10 CFR 50 LOCAL TENDING OF EMERGENCY DIESEL GENERATORS (Original Submittal August 10, 1984)

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FIRE PROTECTION - EXEMPTION REQUESTS AND MODIFIED COMMITMENTS - REVISION 5 INDEX FOR ATTACHMENTS December 28, 1984 NRC NEW INFORMATION APPROVAL THIS SUBMITTAL ATTACHMENT STATUS YES/NO TITLE 14 OPEN YES EXEMPTION REQUEST - SECTION III.G.2 OF APPENDIX R TO 10 CFR 50 INSTRUMENT SEPARATION INSIDE CONTAINMENT (Original Submittal July 16, 1984 - Rev 1 December 28, 1984) 15 OPEN NO EXEMPTION REQUEST - SECTION III.G.2 OF APPENDIX R TO 10 CFR 50 CABLE SEPARATION INSIDE CONTAINMENT (Original Submittal July 20, 1984)

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ATTACHMENT 1 Consumers Power Company Palisades Plant - Docket 255 EXEMPTION REQUEST - SECTION III.G.2 OF APPENDIX R TO 10 CFR 50 INSTRUMENT SEPARATION INSIDE CONTAINMENT Original Submittal - July 16, 1984 Revision 1 - December 28, 1984 Revision 2 - August 10, 1984 Revision 3 - December 28, 1984 2 Pages FP0484-0001C-NL02

ATTACHMENT 1 APPENDIX R REVIEW PROCESS 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 1 of our January 18, 1984 submittal. This understanding is supplemented by the following:

0 Cable Separation - Cold Shutdown Engineering judgement and analysis may be used to demonstrate that one train of cold shutdown equipment is free of fire damage (i.e. it is conservative but overly restrictive to apply Appendix R,Section III.G.2 separation criteria to cold shut-down eq~ipment). (NRC Staff Guidance, April 24, 1984 meeting, Bethesda, Maryland.)

0 Manual Operator Actions in Fire Area of Concern In order to demonstrate safe shutdown capability, it is accept-able to rely on manual operator actions in the fire area of concern (e.g., room where fire initiated) provided the plant will not reach an unsafe or unrecoverable condition (i.e., if it can be demonstrated that sufficient time exists to detect fire, extinguish fire, and manually operate equipment prior to reaching an unsafe or unrecoverable plant condition, then such operator actions are consistent with Appendix R requirements.)

(Conference call Mr TV Wambach (NRC) and Mr L W Bauer (CPCO).)

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

c. Define fire area (per Generic Letter 83-33, October 19, 1983). This process is illustrated by Appendix A, 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 50.

(The safety functions are: reactivity control, inventory control, heat removal, and process monitoring.) This process is illustrated by Appendix A, 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."

FP 1184-0001-NL02

ATTACHMENT 1 APPENDIX R REVIEW PROCESS

2

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

f. Evaluate cable separation. This process is illustrated by Appendix A, 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. In the example provided, train "A" and train "B" each have equipment in the same fire area and therefore cannot be considered redundant systems in accordance with 10CFRSO, Appendix R requirements.

DIFFERENCES FROM APPENDIX R Differences exist between the protective measures prescribed by Appendix R and the protective measures available at Palisades Plant. Resolution is 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 protec-tion 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.

Plan modifications which are a direct result of Appendix R compliance are described in Attachment 8. Technical exemption requests are provided in Attachments as identified in the attachment index.

FP1184-0001-NL02

APPENDIX A OF ATTACHMENT 1 Consumers Power Company Palisades Plant - Docket 50-255 ILLUSTRATIONS, APPENDIX R REVIEW PROCESS Original Submittal - December 28, 1984 8 Pages FP0484-0001X-NL02

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ATTACHMENT 14 Consumers Power Company Palisades Plant - Docket 255 EXEMPTION REQUEST - SECTION III.G.2 OF APPENDIX R TO 10 CFR 50 INSTRUMENT SEPARATION INSIDE CONTAINMENT Original Submittal -July 16, 1984 Revision 1 -December 28, 1984 3 Pages FP0484-0001C-NL02

ATTACHMENT 14 EXEMPTION REQUEST - SECTION III G.2 OF APPENDIX R TO 10 CFR 50 INSTRUMENT SEPARATION INSIDE CONTAINMENT Approval Status NRC review ih progress.

Equipment Under Consideration Steam Generator "A" Pressure (PT-0751A,B,C & D); Steam Generator "B" Pressure (PT-0752A,B,C & D);

Pressurizer Level (LT-OlOlA,B, LT-0102A,B,C & D, LT-0103, LT-0105);

Pressurizer Pressure (PT-0101A,B, PT-0102A,B,C & D, PT-0103);

(Reference Drawings: E-350, E-382 detail C).

Safety Function(s) Of Equipment Process monitoring for steam generator and pressurizer.

Exemption Request III.G.2.d of Appendix R to 10 CFR 50 to the extent that redundant instrumen-tation is required to be separated by a minimum of 20 feet.

Necessary Plant Modification None Justification For Exemption Request A. The room is oddly shaped with a 13~ foot high ceiling extending up to 34 feet in the area of the staircase. Totai volume is approximately 14,420 cubic feet~ The walls, floor and ceiling are constructed of poured, reinforced concrete. The room is on the 590' elevation of containment.

The northeast corner contains a metal staircase which goes up only. There are two unrated, but substantial, steel doors in the room that lead to other areas of containment. The room is well ventilated by natural circulation supplemented by forced circulation (i.e. HVAC).

The room's construction provides a massive heat sink that would absorb the heat from a fire. The ventilation would dissipate the heat quickly.

The instruments of concern are located on the east wall opposite the 480V pressurizer heater load centers. The instruments are listed above.

Equipment locations are shown in the attached drawing (E-382 detail C).

B. The instruments have steel or aluminum cases and all wiring to them is run in conduit from cable trays. The casings and conduit effectively act as a radiant energy shield. The case is a hollow steel or aluminum shell which covers, but does not directly touch, the sensing device.

FP1084-0001-NL02 4

Exemption Request

2 A radiant energy shield is a noncombustible material which blocks the path of radiant energy from the fire to the instrument of concern. The cases are made of steel or aluminum and conduit are made of steel and thus noncombustible. The cases and conduit surround the instruments and cable thus blocking radiant energy from reaching them. The instruments are LOCA qualified. This qualfication provides added assurance that the instruments can operate under harsh environmental conditions (e.g. high temperature, high humidity).

C. This room is in cont~inment. Access is severely limited. During operation, personnel entering containment they wear full Anti-C's and Self Contained Breathing Apparatus. They dress and undress outside of containment. There are no "step-off" pads and no discarded Anti-C's inside of containment during operation. Everything is stored or discarded outside of containment when the plant is operating.

Smoking is strictly prohibited in containment during plant operation by Administrative Procedures 7.03. In fact, it is impossible because of the self contained breathing apparatus worn by personnel. Flammable liquids are not brought into containment during operation because they are not needed for anything.

D. Combustible loading in this room is light, consisting of small amounts of cable in trays. The trays and cables are located above the instruments.

There are no combustibles at the floor level. Heat and smoke from an in-situ fire would be above the instruments. There are no transient sources of ignition.

E. Strict administrative controls dictate that all loose material be removed from containment prior to startup to prevent containment sump plugging and transient fires. Administrative Procedure Number 4.04, Revision 0, "Plant Housekeeping" states "Prior to startup following any significant mainten-ance work, the containment building shall be given a thorough inspection for any unnecessary debris which could wash into the containment sump and plug the recirculation path during post-LOCA conditions. Particular attention should be given to the 590 1 level. In addition, material which could pose a fire threat shall be removed."

Two other procedures also assure that there are no transient combustibles in containment. They are:

1. Operations Checklist 1.3 Revision 4, "250 Pound Heat-Up Checklist, Containment Building" states "Complete a walk through of the contain-ment building to ensure that transient combustibles and/or flammable materials have been removed."

2. Fire Protection Implementing Procedure Number 7 Revision 3 "Fire Prevention Activities" states "Combustible materials shall be removed as soon as possible after use to keep the amount of combustibles as low as possible." It also states "The person responsible for the work activity in a safety related area shall assure the removal of all waste, debris, scrap, rags, oil spills or other combustibles resulting FP1084-0001-NL02 4

Exemption Request

3 from the work activity, or at the end of each work shift, whichever is sooner." Since the containment building is a safety related area, the procedure applies to work activities in the containment building.

Thus, three procedures assure that there are no transient combustibles in the air room during operation. There are no sources of ignition in the air room. Therefore, a transient combustible fire is virtually impossible in the air room.

F. Smoke detectors are installed in the room and alarm automatically in the control room. A fire hose is readily available to the room. Portable fire extinguishers are also readily available. The fire brigade will respond immediately upon receipt of the alarm.

G. Consumers Power Company concludes, based on the reasons above that a transient fire in the air room will not occur and the present arrangement of the instruments in the containment air room is adequate that an exemption from the requirements of Appendix R, section III.G.,should be granted.

FP1084-0001-NL02

ML18051B132

Text

SUMMARY

SUMMARY

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