ML18054B507

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Requests Schedular Exemption to 10CFR50,App R,Section III.G.2 Re Containment Air Room Until Automatic Suppression Sys Installed.Upon Schedular Exemption,Util Will Withdraw Mentioned Exemption Requests Filed on 851004 & 890111
ML18054B507
Person / Time
Site: Palisades 
Issue date: 03/13/1990
From: Smedley R
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TAC-71852, NUDOCS 9003260265
Download: ML18054B507 (7)


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MICHIGAN'S PROGRESS General Offices: 1945 West Parnall Road,Jackson,"MI 49201*(517)788-0550 March 13, 1990 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

REQUEST FOR TEMPORARY EXEMPTION -

CONTAINMENT AIR ROOM - APPENDIX R (TAC NO 71852)

Consumers Power Company submitted 10CFR50 Appendix R exemption requests regarding the Containment Air Room on October 4, 1985 and January 11 1989.

The staff has informed Consumers Power Company by telephone that, after further review, they have determined the requested exemptions will not be approved.

After evaluating the various modifications which could be installed to comply with the criteria of Section III.G.2, Appendix R 10CFR50, Consumers Power Company determined that automatic fire suppression would be installed in the Containment Air Room.

Since fire detection already exists in that area, installation* of fire suppression will bring the area into compliance with the criteria of 10CFR50 Appendix R Section III.G.2.e.

Consumers Power Company will install automatic fire suppression in the Containment Air Room before the end of the next refueling outage which is presently scheduled from September 1, 1990 through the end of January 1991.

This commitment is based on the assumption that control valves can be received in time to support installation during this period.

The valves must be environmentally qualified per 10 CFR 50.49 since they must close during a MSLB or LOCA to limit sump level or prevent uncontrolled dilution of the borated sump water.

If problems arise which prevents Consumers Power Company from meeting the refueling outage installation schedule, the NRC will be notified.

Conceptual plan and sectional views of the suppression system (Attachment 1) were forwarded to the Staff for comment.

The Staff indicated they could approve the design of the installation if their comments and questions regarding the design were appropriately answered or included in the design basis.

The NRC questions or comments and Consumers Power Company's response are as follows:

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PDC OC0290-0256-NL04 A CM5 ENERGY COMPANY

Nu.clear Regulatory Commission Palisades Plant Req For Temp Exemption March 13, 1990

1.

"Does the proposed design conform to NFPA 13?"

Response

The system will conform to NFPA 13.

There will be minor exceptions basically dealing with the shutoff valve arrangement.

Consumers Power Company believes these exceptions are permitted by the NFPA 13 language "new technologies or alternate arrangements, providing the level of safety prescribed by the standard is not lowered."

2.

"The NRC would like Consumers Power Company to use 165°F heads."

Response

Consumers Power Company will use 165°F heads.

3.

"Are baffle plates needed above sprinkler heads to collect heat?"

Response

Baffles are not needed for 4 of the 6 heads.

These heads will be located within inches of a smooth concrete ceiling.

The ceiling provides an adequate heat collector.

The two heads in the stairwell will have baffle plates.

4.

"Will the spray radius (7.5') cover all instruments concerned?"

Response

Yes.

Sprinklers can protect up to 225 sq ft with a 15' spacing.

Most instruments will be much closer than 7.5'.

5.

"Are there any other obstructions to sprinkler head discharge?"

Response

No, NPFA 13 allows up to a 4' wide obstruction beneath the sprinklers without having to place a sprinkler beneath it. All obstructions are less than 4' wide and will not impede the sprinkler discharge.

To clarify our Appendix R compliance status, Consumers Power Company hereby requests a schedular exemption to 10CFR50 Appendix R Section III.G.2, as it pertains to the Containment Air Room, until an automatic suppression system is installed.

The justification for this schedular exemption is explicit in our November 4, 1985 request for a permanent exemption.

Upon receipt of the OC0290-0256-NL04 2

Nuclear Regulatory Commission Palisades Plant Req For Temp Exemption March 13, 1990 schedular exemption, Consumer Power Company will withdraw the mentioned exemption requests filed on October 4, 1985 and January 11, 1989.

Richard W Smedley Staff Licensing Engineer CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment OC0290-0256-NL04 3

OC0290-0256-NL04 ATTACHMENT 1 Consumers Power Company Palisades Plant Docket 50-255 CONTAINMENT AIR ROOM FIRE SUPPRESSION SYSTEM March 13, 1990 3 Pages

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