ML19249A973

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Discusses Incorporation of Alternate Shutdown Sys Design & Installation Into SEP Efforts.Requests Issuance of Suppl to Fire Protection Ser,Table 3.1.Suggests Prompt Action
ML19249A973
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 08/24/1979
From: Bixel D
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To: Ziemann D
Office of Nuclear Reactor Regulation
References
TASK-07-03, TASK-09-06, TASK-7-3, TASK-9-6, TASK-RR NUDOCS 7908280007
Download: ML19249A973 (2)


Text

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Consumers Power 4

Company

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General Offices. 212 West Michigan Avenue Jackson, Michigan 49201 e Area Code 517788-0550 a

August 24, 1979 Director, Nuclear Reactor Regulation Att Mr Dennis L Ziimann, Chief Operating Reactors Brarch No 2 US Nuclear Regulatory Commissica Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT - FIRE PROTECTION MODIFICATIONS: ALTERNATE SHUTDOWN PANEL Amendment 25 to License DPR-6 requires that certain modifications be made to the Big Rock Point Plant for fire protection purposes. The modifications are described in the Fire Protection Safety Esaluation (SE) forwarded with Amendment 25.

Amendment 25 states, in part, "These modification will be completed in accordance with Table 3.1 of the SE and supplements thereto."

Item 3.1.1 of Table 3.1 of the Fire Protection SE is an alternate safe shutdcwn system. This letter requests that a supplement to Table 3.1 ae issued incorporating the installation of this alternate system with modifications which might be required as a result of the Systematic Evaluation Program (SEP).

Ongoing reviews related to certain topics in the SEP program (eg, VII-1.A -

Isolation of Reactor Protection System from Nonsafety Systems, VII Systems Required fc r Safe Shutdown, VII Effects of Failure in Nonsafety Related Systems on Selected Engineered Safety Features, and XV Loss of All A-C Power) could require modifications that will impact the size, location, or detailed engineering design of the alternate shutdown system. Backfitting of modifications to the alternate shutdown system would

',e extremely difficult since the area wherein the panel associated with this system is to be located is n,t large enough to accommodate an increase in panel size. No other area is available where the panel can be located and still maintain adequate separation from other shutdown systems to satisfy fire protection concerns.

Any increase in panel size resulting from yet-to-be-determined SEP requirements would likely cequire a new structure to be built. Still other SEP topics could affect the size and location of any new structure and, thus, information available at this time is inadequate to design and build such a structure. Similar sizing and design constraints apply to the new d-c power supply associated with the alternate safe shutdown system.

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Chsnges to an existing installation to resolve any concerns raised during SEP review would be possible but undesirable. As discussed above, such changes would be likely to result in an alternate shutdown control panel in two parts, physically separated from each other.

Consumers Power Company considers that incorporating the alternate shutdown system into design changes necessitated by SIP would result in a s9-tem which better addresses all concerns.

To permit incorporating alternate shutdown system design an.1 installation into SEP efforts, Consumers Power Company requests that a supplerent to the Big Rock Point Fire Protection Safety Evaluation, Table 3.1, be issued stating that Item 3.1.1 has been incorporated into the Systematic Evaluation Program and that the detailed schedule is currently under development. Sin,e other modifications listed in Table 3.1 to provide improved fire protec.on will be accomplished in accordance with the schedule therein, Consumers Power Company considers that the proposed delay in alternate shutdown system installation does not result in an unacceptable risk to public health aid rafety.

Installation of the proposed alternate safe shutdown system in accordance with the schedule currently included in Taole 3.1 would require procurement of certaia items of equipment and start of fabrication in the near future. To prevent unnecessary ef fort, prompt action on this request would be appreciated.

David A sixel (Signed)

David A Bixel Nuclear Licensing Administrator CC JGKeppler, USNRC