ML20002C821
| ML20002C821 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 10/28/1977 |
| From: | Bilby C, Bixel D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Desiree Davis Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20002C822 | List: |
| References | |
| NUDOCS 8101120078 | |
| Download: ML20002C821 (6) | |
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Att: Mr Don K Davis, Acting Eranch Chief 2
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Director of Nuclear Reactor Regulation
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REVISED FIRE PROTECTION T/S Transmitted herewith are three (3) original and thirty-seven (37) confor:ed ccpies of a preposed change to the Tec'anical Specifications of License DFR-6.
Docket 50-155 issued to Consu=ers Power Company on May 1, 1964 for the Big Rock Point Plant. This prcpesal supersedes our Technical Specifications change request dated March 29, 1977 concerning fire protection require =ents and is based on the revised sa=ple Technica?. Specifications forwarded to Consu=ers Power Co=pany by letter dated June 24', 1977.
m David A Bixel Nuclear Licensing Administrator CC: JGKeppler, USIGC
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CONS'JMERS POWER CCMPANY -
Docket 50-155 Request for Change to the Technical Specifications License DFR-6 For the reasons hereinafter' set forth, it'is requested that the Technical 4
Specifications contained in Facility Operating License DER-6, Docket 50-155, be changed as described.in Section I.below:
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Changes' d
A.
Replace Figure 6.2-1 with new Figure 6.2-1.
,B.
Section 6.2.2.
1.
Add Section 6.2.2.f.
C.
Section 6.b.
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- 1. lIn Section 6.h.1 replace " Nuclear Training Administrator" with '" Plant Superint,endent."
2.
Add Section 6.h.2.
D.
Add Sections 6.5.2 9.e, f, g.
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The Facility Fire Protection Progra= and implementing procedures at ler.st once per 2 years.
f.
An independent fire protection and loss prevention inspection and j
JLudit shall be performed annually utilizing either qualified off-site licensee personnel or an outside fire protection firm, i
g.
An inspection and audit of the fire protection and loss prevention program shall be performed by an outside qualified fire consultant at intervals no greater than 3 years."
E.
Add new Pages 150 through 158.
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II.'-Discussion The proposed Fire System Technical Specifications for Big Rock Point are lased'on the sample Technical Specifications dated June 2h, 1977 Modifica-tions have been made to suitably adapt the revised sa=ple Technical Spec-ifications dated June 2k, 1977 for use. These modifications generally consist of rewording and reva= ping sample recommendations to be consistent with those already in effect in the. Big Rock Point Technical Specifications or procedures, and deleting those that are not applicable or appropriate.
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(.v The following is a section-by-dection discussion of the proposed Technical Specifications.
1.
Administrative Controls Changes as presented in the revised sa=ple Technical Specffications are incorporated as applicable to the Big Rock Point Plant.
2.
hstrumentation - Fire Protectier.
Table 3 3.8 lists all fire detection equipment currently installed for safety-related systems at Big Rock Point. The minimum number of opel-able instruments.was derived by considering the area of detection in-fluence of each detector and correlating that to the nu=ber necessary to ensure full detection in each specific area, based on the hazards involved. Ccncerning the action items, the requirement to submit a special report to the Co= mission within 10 days concerning the circumstances of, and restoration procedures for, the inoperable detectors is inconsistent wit'. other reportable items. The conditions prescribed by this sample recommendation meet the criteria established for the 30-day written reports in Section 6.9 2.b of the current Technical Specifications, and are considered adequate. This applies throughout this submittal. Currently, there are no NFPA Code 72D Class A supervised circuits installed at Big Rock Point. Therefore, the surveillance requirements concerning these are not appropriate a*.1 the six-month cht.nnel functional test is considered adequate.
3 Fire Surtressit Water System At Big Rock Point the Emergency Core Cooling System (ECCS) utilizes the electric aid diesel-driven fire pu=ps and associated piping. Thus, it was necessary to reva=p the sa=ple Technical Specifications to be consistent with the ECCS Technical Specifications requirements of Sec-tion 11.3.1.h.
Wherever action items concerning fire suppression sys-tems, as recommended in the sample, are already incorporated or exceeded in existing ECCS Technical Specifications, the required ECCS action was considered appropriate and, therefore, not included in this section.
Concerning surveillance require =ents pertinent to this section, several changes frem the sample Technical Specifications are necessary. There
- C are no sterage tanks for fire wa :c at Big Rock Point. Therefore, the 2
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water level in the Intake Bay which is fed by Lake Michigan will be monitored. The 570' elevation was derived by determining the minimum suction level required for the-fire pu=ps.
The monthly requirement for running the fire pumps was altered in the proposed Technical Specifications to 5-minute run time for the electric pump and 30-minute run time for the diesel pump. This allows for sufficient run time to bring both pu=ps to operating temperature and thereby ensure proper l
operation. Since the term " Staggered Test Basis" is not defined in the Big Rock Point Technical Specifications, it has been deleted from the proposal.. However, these changes adequately meet the intent of the sample. recommendations. Since all fire system valves at Big Rock Point are hand operated, the requirement for operating testable valves was deleted. Past experience has shown that there have been no fire water flow degradation problems at Big Rock Point and water conditions do not dictate a need to perform system flushes in a 6-month interval and, therefore, this requirement is shifted to a refueling outage periodicity.
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Fire Scray and/or Serinkler Systems As stinulated in Section 2, the sample requirement for a lO-day written report to the Co= mission was considered inappropriate and would be better served as a 30-day written report in accordance with Section 6.9 2.b of the current Technical Specifications.
Concerning surveillance items, the sample recommendation for cycling each testable valve was again deleted from the proposal since Big Rock Point presently has none that meet this criteria. The sa=ple recommendationforayearlyfunctionaltestforthesprayand/or sprinkler system was deleted. There exists no means of performing a functional test or s1=ulating automatic actuation of these systems.
The yearly requirements to inspect the spray headers for integrity and each nozzle for external blockage are proposed in accordance with the sample reco=mendation.
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5 c02 System
. The sample Technical Specifications for CO2 systems have been deleted from the-proposal since no CO2 systems are used at Big Rock Point for the systems discussed.
6.
Halon Systems The sample Technical Specifications for Halon systems have been deleted from the proposal since no Halon systems are used at Big Rock Point for the systems discussed.
7.
Fire Hose Stations The proposed Technical Specifications concerning fire hose stations are consistent with the sample Technical Specifications with two ex-ceptions. The action item requiring routing of an additional hose from an operational station to the unprotected area has been modified to require providing an additional hose at an operation station. This will ensure that the area with an inoperable hose station will be ade-quately covered by the additional hose available at the operational station, yet the passageway will not be obstructed by fire hose.
Ad-ditionally, it will ensure that the integrity of the additional fire hose is maintained since it will remain coiled and not subject to inadvertent damage. And, since there are no standpipes in use at operating hose stations, or elsewhere, any mention of standpipes cc its associated pressure has been deleted from the proposed Techr.ical Specifications.
8.
Fire Parrier Penetration Fire Seals Since no fire btrrier penetration seals at Big Rock Point act as pressure boundaries, the requirement for leak testing after repair is unnecessary. This sample recommendation has been deleted from the proposal.
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2 III. Conelusion Based on the foregoing, both the Big Rock Point Plant Review Cocnittee and the Safety and Audit Review Board have concluded that this change does not
' involve an unreviewed safety question.
CONSUERS POWER C@lPANY e
By C R Bilby, Vice Prp dent Production & TransbYssion Sworn and subscribed to before me this 28th day of October 1977 dA_)
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' Linda R Thayer, Notar/ Public Jackson County,' Michigan My_coc=ission expires July 9, 1979 i.
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