ML19345C930
| ML19345C930 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 11/14/1980 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19345C929 | List: |
| References | |
| NUDOCS 8012080630 | |
| Download: ML19345C930 (6) | |
Text
d-ENCLOSURE 1 SUPPLEMENT NO. 3 TO THE APRIL 4,1979 FIRE PROTECTION SAFETY EVALUATION REPORT
_BY THE OFFICE OF NUCLEAR REACTOR REGULATION U. S. NUCLEAR REGULATORY COMMISSION FACILITY OPERATING LICENSE NO. OPR-6 CONSUMERS POWER COMPANY BIG ROCK POINT PLANT DOCKET N0. 50-155 Date: November 14, 1980 g012080 63o--
'i INTR 0CUCTION j
On April 4,1979, the Commission issued Amendment No. 25 to Facility Operating License No. DPR-6 for the Big Rock Point Plant. This amend-ment added a condition to the license which required completion of the J.
. modifications identified in Paragraphs 3.1.1 through 3.1.29 of the NRC's i
~ Fire Protection Safety Evaluation (FPSE) for the Big Rock. Point Plant
- dated April 4,1979.
By letter dated August 24, 1979, the licensee requested a delay in the implementation of the Alternate Shutdown Panel Item 3.1.1 of Table l
3.1 of the FPSE until' completion of the Systematic Evaluation Program.
The original implementation schedule in the FPSE is October -31,1980.
This supplement to the FPSE acHresses this proposed implementation L
schedule change and the impact of the pr ced Appendix R to 10 CFR Part j
50 on the licensee's request.
t -
In Table 3.2 of the FPSE, certain items were identified as incomplete i
and requiring further information from the licensee and evaluation by i
the NRC staff. This supplement to the FPSE also addresses those items T
that were identified as inccmplete.
I DISCUSSION AND EVALUATION J
The section numbers indicated are those corresponding to the section numbers in the FPSE.
3.1.1 Alternate Safe Shutdown System By letter dated August 24, 1979, the licensee requested that the imple-j mentation date of the alternate safe shutdown system be deferred until the completion of the Systematic Evaluation Program (SEP) review. The reason provided by the licensee for deferring the schedule for this item is that various topics currently being reviewed in the SEP (e.g., Topic L
- VII-1.A Isolation of Reactor Protection System from Ncn-Safety Systems; Topic VII-3, Systems Required for Safe Shutdown; Topic VII-4, Effects
.of Failure in Non-Safety Related Systems on Selected Engineered Safety Features, 'and Topic XV-24,' Loss of All A-C Power) may result in additional requirements or modifications of the alternate shutdown capability.
Because the SEP requirements could affect.various parameters (e.g.,
i location, size,' detailed engineering design), adequate information is j
not available to design a system to meet all possible requirements.
r The SEP is scheduled to be completed by April 1982. However, the Commission's Memorandum and Order dated May 23, 1980 notes that the E
proposed Appendix R to 10 CFR Part 50 specifies December 1,1981 as the proposed implementation date for alternate shutdown capability
. and October 1,- 1982 for dedicated shutdown capability for plants, e
including Big Rock' Point, that are under review in the Systematic Evaluation Program.. Accordingly, we have concluded that a delay until r+-
y-
--.--r 7%3
,y-
~---, -..,.
.,,,s
.-,.----.,,,.---.r
,w-,-.
-w.-~
r-
. 4 the completion of the Systematic Evaluation Program as requested by the licensee 'is not appropriate; rather, we believe that any considce-ation for a delay in the scheduled implementation of alternate shutdown capability should be in the context of the provisions of the proposed ^
Section 50.48 of 10 CFR 50 and its Appendix R.
Because of the fire modifications that have been implemented and the remainder that will be completed.in the near future (see Table 3.1),
the increase in fire brigade size to five trained members, the adminis-trative controls in effect, and the possible changes in the requirements for the alternate shutdown capability that may be identified over the next year, we conclude that the completion date of the alternate safe shutdown system shall be governed by che requirements of Section 50.48 of 10 CFR-50 when it becomes effective.
3.2.1 Fuel Pool Cooling In Section 4.16~ of the FPSE, we stated that because of the lack of separation criteria for electrical cabling of redundant systems, postulated fires in various areas may result in loss of redundant cooling systems for the spent fuel pool. We stated that the resultant 1
boiling that may occur would cause a gradual decrease in water level of the spent fuel pool but that this water could be adequately reple-nished by a fire hose. However, we indicated that the structural effects on the spent fuel pool d ? to boiling had not been evaluated by the licensee.
By letter dated December 28, 1979, the licensee provided additional information and by letter dated June 20, 1980, Consumers Power Company submitted an analysis performed by NUS Corporation regarding the effects of pool boiling on the concrete structure, racks, and liner of the spent fuel pool in the event that both pumps in the spent fuel cooling -
system should fail. The analyses show that-the stresses that develop under these conditions are within design limits. We have reviewed the analyses and concur in its conclusions. We find that the fire protection for this area conforms to the guidelines in Section 2.0 of the FPSE and is, therefore, acceptable.
i The other two items listed in Table 3.2 of the-FPSE have previously been resolved satisfactorily.
Item 3.2.4, Fire Brigade, was resolved by issuance of Amendment No. 32 dated March 27, 1980, which increased the minimum fire brigade size from three to five trained members.
Item 3.2.3, Cabling in the Recirculation Pump Area, was resolved as
- discussed in our Safety Evaluation issued March 11, 1980.
CONCLUSION Becau3e of the fire protection modifications that have been implemented and those that will be implemented in the near future, the increase in fire brigade size to five trained members, the administrative controls in effect, and the possible changes in the requirements for the alternate shutdown capability that may be identified over the next year, we conclude that' a deferral of the alternate safe shutdown system until 1
i
. the date specified in the revised 10 CFR 50.48 is acceptable. We further conclude that this deferral will not result in an unacceptable risk to the health and safety of the public and it does change conclusions made in the FPSE dated April 4, 1979, therefore, Table 3.1 is modified by this Supplement as indicated.
We also conclude that all the incomplete items in the FPSE except the design of the alternative safe shutdown capability have been acceptably resolved subject to the implementation of the remaining proposed modifi-cations shown on Table 3.1 of the enclosure.
Enclosure Table 3.1
TABLE 3.1 Implenentation Dates for Proposed Modifications Modification Implementation Date 3.1.1 Alternate Safe Shutdown System 3.1. 2 Interim Measures Completed 3.1.3 Fire Detection Systems 3.1.4 Fire Pump Header 3.1.5 Fire Apparatus Drafting Site Completed 3.1.6 Diesel Fire Pump Protection Completed 3.1.7 Fire Hose Statiens 3.1.8 Protection Against Water Spray Completed 3.1.9 Fire Extinguishers Completed 3.1.10 Transformer Water Spray 3.1.11 Breathing Apparatus Completed 3.1.12 Battery-Powered Emergency Lights Completed 3.1.13 Fire Barrier Penetrations 3.1.14 Cable Spreading Area Ladder Completed 3.1.15 Valves for Containment Hose Stations 3.1.16 Steel Drums for Radwaste Completed 3.1.17 Fire Hose Fittings Completed 3.1.18 Protective Clothing Completed 3.1.19 Fire Equipment Storage Completed 3.1.20 Hose Station Modifications Comoleted 3.1.21 Fire Hydrant Inspection Completed 3.1.22 Fuel Tank Access Completed 3.1.23 Recirculation Pump Area Sprinkler 3.1.24 Portable Smoke Exhauster Completed 3.1.25 Shutdown Cooling Valves Completed 3.1.26 Protection of RDS Cables Completed 3.1.27 Fire Door Closure Devices Completed 3.1.28 Fire Fighting Procedures Completed 3.1.29 Quality Assurance Completed
- Refueling outage required to complete. Work to be completed prior to startup from 1980 refueling outage. Outage currently scheduled to begin on October 31, 1980.
- To be in conformance with the provisions of the revised 10 CFR 50.48.
ENCLOSURE 2
SUMMARY
OF NRC STAFF POSITION i
BIG ROCK POINT 50-155
'3.1.1 Alternate Safe Shutdown System
)
In' the Fire Protection Safety Evaluation Report it was our corcern that in several areas redundant systems could be damaged by a single fire tnus the possibility of affecting safe shutdown.
The licensee has not demonstrated that adequate protection features have been provided for cables and. equipment of redundant systems important to achieving safe shutdown conditions to ensure that at least one means of achieving such conditions survives postulated fires.
To meet our fire protection. guidelines, alternate shutdown capability should
)
j be provided when safe shutdown cannot be ensured by barriers and detection and suppression systems because of the exposure of redundant safe shutdown equipment cabling, or components in a single fire area, to an exposure fire, t
or fire suppression activities, or rupture or inadequate operation of fire i
suppression' systems.
j, To meet Section III, Paragraph G of proposed Appendix R to 10 CFR Part 50, the licensee should provide alternate shutdown capability for the following areas of the plant:
1.
Control Room 2.
Electrical Equipment Room 3.
Exterior Cable' Penetration Room 4.
Containment 5.
Auxiliary Boiler. Room 6.
Turbine Generator Room The alternate shutdown cystem should meet the requirements of Section III, Paragraph L of proposed Appendix R to 10 CFR Part 50.
i i
j' l
i-f 4
f
(
l
'