ML18051B474
| ML18051B474 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/12/1985 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML18051B473 | List: |
| References | |
| NUDOCS 8507170454 | |
| Download: ML18051B474 (3) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 O!CLOSURE 2 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RFLATTVE TO APPENDIX P EXEMPTIONS REQUESTED FOR PALISADES PLANT DOC~ET NO. 50-?.55
1.0 INTRODUCTION
By lP.tter dated July 16, 1984, as amended by letters dated July 20, 1984, August 10, 1984, Octobe~ 1, 1984, December 28, 1984, March 19, 1985 and Ju~e 19, 1985, the Consumers Power Company (the licensee) requested exemptions from Section III.G of Appendix R to 10 CFR Part 50, Section III.G.2 of Appendix R requires that one train of cables and equipment necessary to achieve and maintain safe shutdown be maintained freP. of fire darn~ge by one of the followinq means:
- a.
Separation of cables and equipment anrl associated nonsafety circuits of redundant trains by a fire barrier having a 3-hour rating.
Structural steel farminq a part of or supporting such fire barriers shall be protected to provide fire resistance equivalent to that required of the barrier.
- b.
Separation of cables and equipment and associated nonsafety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards.
In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area.
- c.
Enclosure of cable and eauipment and associated nonsafety circuits of one redundant train in a fire barrier having a !-hour rating.
In addition, fire detectors an~ an automatic fire suppr~ssion system shall he installed in the fire area.
Jf the above conditions are not met, Sectipn III.G.3 requires that there be -.
- an *a*iternative shutdown capability independent of the fire area of concern.
It also requires that a fixed suppression system be installed in the fire area of conr.ern if it contains a large concentration of cable or other combustibles. These alternative requirements are not dePmed to be equivalent; however, they provide equivalent protection for those configurations in which they are accepted.
Because it is not possible to predict the specific conditions under which fires may occur and propagate, the desiqn-basis protective features rather than the desi~n-basis fire are specified in the rule.
Plant-specific features may require protection different from the measures specific in Section rrr.li.
In such a case, the lic.ensee must demonstrate, by means of
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a detailed fire hazards analysis, that existing protection or existing protection in conjunction with proposed modifications will provide a level of safety equivalent to the technical requirements of Section !1!.G of Appendix R.
In summary,Section III.G is related to fire protection features for ensurina that svste~s and associated circuits used to achieve and maintain safe sh~tdown a~e free of damage.
Either fire protection configurations must meet the specific re~uirements of Section III.Goran alternative fire protection configuration must be justified hy a fire hazard analysis.
Generally, the staff will accept an alternative fire protection configuration if:
- 1.
The alternative ensures th~t one train of equipment necessary to achieve hot shutdown from either the control room or emergency control stations is free of fire damage.
- 2.
~
- 4.
The alternative ensures that fire damage to at least one train of equipMent recessary to achieve cold shutdown is limited so that it can be repaired within a reasonable time (minor repairs using components storP.d on the site).
Fire-retardant coatings are not used as fire barriers.
r1odifications required to meet Section III.G would not enhance fire prct.~rtion safety Jevels above that provided by either existing or proposed alternatives.
- 5.
Modifications required to meet Section III.G wou1d be detrimental to overall facility safety.
2.0 ENGINEERED SAFEGUARDS PO()~/CORRIDOR BETWEEN THE CHARGING PUMP ROOM AND THE it SWITCHGEAR ROOM ELEVATION 590'-0" OF THE REACTOR BUILDING 2.1 Exemption Requested Exemptions were requested from Section III.G.3 to the extent it requires
- a fixed fire suppression system be insta1le~ in areas for which alternate shutdown capability is provided.
2.2 Discussion
- a.
Engineered Safeguards Room Tf'>P.
F.n~ineered Safeguards Room is located on elevation 590 1-0" of the Reac'f:C'r Buildin9.
The room is separated from other plant areas by 3-hour fire rated barriers.
The doors leading into the room are water tight doors.
The
\\'tater +.i0ht doors were reviewed and approved by the staff il1 the Appendix A to. BTP APCSB 9.5-1 SER issuP.d September 1, 1978.
The combustible 10ading in the arP.a is moderate. A fire detection system and manual suppression equipment are provided in the area. There is alternative shutdnwn capability, independent of this' area.
- b.
Corridor between the Charqina Pump Room and the IC Switchgear Room React0r Building Elevation 590 1-0" The combustible loadinq in the area is moderate.
A fire detecti0n syste~
and manual supprP.ssion equipment are provided in the area. There is alternative shutdown capability, independent of this area.
2.3 Evaluation The fire protection in these areas does not conply with the technical require-nents of S~ction III.G.3 of Appendix P because fixed fire suppression systems have not been installed in the areas.
ThP.re is reasonable assurance that a fire in these areas would be promptly dP.tP.cted and extinguished.
The moderate combustiblP. loading in these areas ensures that safety-related equipment in adjacent areas will not be threatened.
NRR and Region III fire protection engineers recently visited the site to walk down the fire protection modifications mace t:iy the licensee to comply with A.ppendix R and to review the above two areas where exemptions from Appendix R had been requested.
Based on the licensee's analysis and the review of the areas at the site the staff concludes that the installation nf a fixed fire suppression system would not siqnificantly increase the level of fire protection in these areas.
?.
- tt Con cl us ion Based on the above evaluation, the staff finds that the existing fire protection combined with the ~lternate shutdown capability in the Engineered Safeguards Room and the Corridor between the Charging Pump Room and the lC Switchgear Room in the Reactor Building elevation 590 1-0" provides a level of Rrotect_ion _equivalent to the technical requirements of Section III.G.3 of Appendix R.
Therefore, the exeMption should be granted.
3.0 ACKNOWLEDGEMENT This safety evaluation was prepared by John Stang.
Dated: July 12, 1985