ML20008E812
| ML20008E812 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/10/1981 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20008E807 | List: |
| References | |
| NUDOCS 8103090762 | |
| Download: ML20008E812 (7) | |
Text
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O SUPPLEMENT NO. 2 TO THE SEPTEMBER 1,1978 FIRE PROTECTION SAFETY EVALUATION REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION U. S. NUCLEAR REGULATORY COMMISSION PROVISIONAL OPERATING LICENSE NO. DPR-20 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET NO. 50-255 Date: Fibrt.ary 10, 1981 8103090 7 @
1.0 INTRODUCTION
On September 1, 1978, the Commission issued Amendment No. 42 to Provisional Operating License No. DPR-20 for the Palisades Plant. This amendment added a condition to the license which required completion of the nodifications identified in Paragraphs 3.1.1 through 3.1.23 of the NRC's Fire Protec-tion Safety Evaluation (FPSE) for the Palisades Plant dated September 1,1978.
By letter dated September 28, 1979, the licensee requested a delay in the implementation of the Independent Shutdown Path, Item 3.1.11 of Table 3.1 of the FPSE until completion of the Systematic Evaluation Program.
The original implementation schedule in the FPSE is October 1980.
This supplement to the FPSE addresses this proposed implementation schedule change and the impact of Appendix R to 10 CFR Part 50 and 10 CFR 50.48 on the licensee's request.
In Table 3.2 of the FPSE, certain items were identified as incomolete and requiring further information from the licensee and evaluation by the NRC staff. This supplement to the FPSE also addresses those items that were identified as incomplete.
2.0 DISCUSSION AND EVALUATION The section numbers indicated are those corresponding to the section numbers in the FPSE.
3.1.5 FIRE BARRIERS Our original concern expressed in our SER was that a single exposure fire could impair redundant cables in the cable spreading room, the switchgear room 1-c, the safeguards area, and the charging oump room. By letter dated April 24, 1980, the Consumers Power Comoany provided information on an open fire protection modification identified as item 3.1.5, " Fire Barriers."
We have reviewed this information for each of the affected areas.
a.
Cable Spreadino Room - Our concern stated in the SER was that an existieg transformer could fail, possibly burn, and, thereby, present an excessive fire hazard for the cable spreading room cables. We regnested that a fire barrier be installed to protect the cables located near the transformer.
The licensee has now stated that the transformer is, in fact, a dry-type and sealed in a nitrogen filled case; therefore, an excessive fire hazard is not present. The licensee has proposed that no fire barrier be required in this area.
Based on our evaluation, we conclude that a fire barrier is not required for the cables near the cable spreading room transformer. The cable spread-ing room has a sprinkler system, smoke detection system, and is separated from the rest of the plant by fire rated wa.ls, floors, and ceiling.
In addition, the licensee will provide an alternate shutdev.n system independent of the cable spreading room. We find that the fire protection for the cable spreading room meets our guidelines, the proposed Appendix R, and, therefore, is acceptable.
. b.
Switchgear Room 1-C - Our concern stated in the SER was that ventilation cuct penetrations in the fire barriers did not have fire rated dampers.
The licensee proposes to install UL listed 3-hour fire dampers and drawings were provided showing locations and construction. We have reviewed this information and determined 'that an appropriate design has been selected.
Based on our evaluation, we conclude that the UL listed 3-hour dampers will adequately protect the duct penetration locations and, therefore, is acceptable.
Safeguards Area - Our stated concern in the SER was that redundant safety c.
system cables could be affected by a single fire exposure. We requested that the licensee provide cable fire barriers to protect one of the systems.
The licensee subsequently performed a detailed study of the cable tray contents and showed that, with two exceptions, only circuits of a single safety system existed in this room. The two exceptions were eliminated by re-routing their conduits outside of the area. Therefore, because redundant cable trays do not exist in this area, the licensee now proposed not to install fire barriers between the cable trays in this area.
Based on our evaluation, we conclude that with the absence of redundant cables in this area the lack of fire barriers is acceptable.
d.
Charging Pumo Room - Our concerns stated in the SER were that redundant cables could be exposed to a single fire and/or that an oil fire could spread between the pumps. The licensee has proposed to install a four-inch curb to contain any oil spills. To preclude the effects of a fire on redundant cables, the licensee will install an alternate shutdown system independent of this area and provide physical adequate se;;aration for the redundant control cables within the area. Sprinklers and smoke detectors will also te provided in this area.
Based on our evaluation, we conclude that the fire protection for this area meets our fire protection guidelines and is, therefore, acceptable.
3.1.11 Alternate safe shutdown systen By letter dated September 28, 1979, the licensee requested that the imple-mentation date of Item 3.1.11 Independent Shutdown Path (alternative safe shutdown system) be deferred untilthe completion of the Systematic Evalua-The reason provided by the licensee for deferring tion Program (SEP) review.
the schedule for this item is that various topics currently being reviewed in the SEP (e.g., Topic VII-1. A, Isolation of Reactor Protection System from Non-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-23, Loss of All A-C Power) may result ii additional requirements or modifications of the alternative shutdown capability. Because the SEP requirements could affect various parameters (e.g., location, size, detailed engineering design), adequate information is not available to design a system to meet all possible requirements.
t
. However, on November 19, 1980, the Cornission issued a revised 10 CFR 50.48 and a new Appendix R to 10 CFR 50 concerning fire protection in nuclear power plants. Section 50.48 specifies a schedule for imple-mentation of modifications necessary to meet the requirements of Appendix R including those asociated with alternative safe shutdown capability.
Therefore, the requested delay until the end of the SEP is unacceptable and the licensee is exp2cted to meet the requirements of 10 CFR 50.48.
3.1.15 REACTOR COOLANT PUMP OIL COLLECTION SYSTE'4 In the SER, it was our concern that an unmitigated lube oil fire could cause loss of cables located in the vicinity of the reactor coolant pumos that may affect safe shutdown.
By letters dated May 2,1980 and September 9,1980, the licensee provided information regarding the proposed reactor coolant pumo oil collection system. An oil collection system will be installed at each reactor coolant pump to collect and contain any leakage or spills from the lift pump, drain and fill plugs, oil level sight glasses, external j
oil coolers, flanged connections in oil lines, and upper and lower oil reservoirs.
Based on our evaluation, we find that the RCP oil collection system meets Section D.2(a)(3) of Aopendix A to BTP 9.5-1 and, therefore, is acceptable.
3.2.2 ADMINISTRATIVE CONTROLS The administrative controls for nuclear plant fire protection consist of the fire protection organization and its cualificaticns, fire brigade training, the controls over corbustibles and ignition sources, methods for assurine the availability of the fire protection systems and equip-ment; procedures for fighting fires, fire watch, and quality assurance provisions for the fire protection crocru. The licensee has provided a description of proposed adninistrative controls for fire ::rotection, as detailed in his subnittals of June 19, 1978, September 29, 1978, March 1,1979, and March 15, 1979. We reviewed this information anif compared it with the specific guidance fcand in " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls, and Quality Assurance" dated June 14, 1977.
We find that the Licensee's Administrative Controls conform to the above referenced guidance, meets the criteria of Appendix A to BTP 9.5.1 and is, therefore, acceptable.
. 3.0
SUMMARY
Status of the Other Open Items in the FPSE 3.1.1 Sprinklers - Approved by letter dated March 11, 1980 3.1.10 Cable Fire Stops - Approved by letter dated March 11, 1980 3.2.1 Cable Penetration Fire Stop Qualification - Approved by Supplement No. I to FPSE issued March 19, 1980 3.2.3 Technical Specifications - Approved and 'ssued by Amendment No. 63 to the license dated August 21, 1980 3.2.4 Fire Brigade - Approved and issued by Amendment No. 60 to the license dated August 21, 1980 3.2.5 Non-approved Components - Approved by Supplement No. I to FPSE issued March 19, 1980 Revised Table 3.1 Table 3.1 of the FPSE is incorporated into the operating license for this facility by the license condition 3.E.
Table 3.1 specifies the completion dates for the modifications required by Paragraphs 3.1.1 through 3.1.23 of the FPSE. All of the modifications but one (3.1.11) have been completed and Table 3.1 has been revised to reflect this. The date for Item 3.1.11, Independent Shutdown Path, has been changed in Table 3.1 to show conformance with the req irements of 10 CFR 50.48 as discussed in a previous section of this supplement.
4.0 ENVIRONMENTAL CONSIDERATION
We have determined that the amendment does not authorize a change in effluent types or total amounts nor an increase in power level and will not result in any significant environmental impact.
Having made this detemination, we have further concluded that the amendment involves an action which is insignificant from the stand-point of environmental impact and, pursuant to 10 CFR 151.5(d)(4),
that an environmental impact statement or negative declaration and environmental impact appraisal need not be prepared in connection with the issuance of this amendment.
5.0 CONCLUSION
We have concluded, based on the considerations discussed above, that:
(1) because the unendment does not involve a significant increase in the probability or consequences of accidents previously considered and does not involve a significant decrease in a safety margin, the amendment does not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (3) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
Date: February 10, 1981 Attached: Table 3.1 i
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TABLE 3.1 l
Implementation Dates for Proposeo Modifications 3.1.1 Sprinklers Completed 3.1.2 Detectors Completed 3.1.3 Cable Penetration Seals Completed 3.1.4 Conduit Penetrations Completed 3.1.5 Fire Barriers Completed 3.1.6 Rerouting of Power and Control Circuits Completed 3.1.7 Fire Door and Sill Completed 3.1.8 Fire Enclosure Completed 3.1.9 Fire and Backdraft Dampers Completed 3.1.10 Cable Fire Stops Completed 3.1.11 Independent Shutdown Path 3.1.12 Emergency Lighting Completed 3.1.13 Battery Room Loss of Ventilation Completed 3.1.14 Equipment Removal Completed 3.1.15 Reactor Coolant Pump Oil Collection System Completed 3.1.16 Portable Smoke Removal Completed 3.1.17 Charging Pump Curb Completed 3.1.18 Fire Brigade Equipment Completed 3.1.19 Yard Area Hydrant Equipment Completed 3.1.20 Hose Stations in the Reactor Containment Building Completed 3.1.21 Supervision of Fire Door Completed 3.1.22 Fire Hose Completed 3.1.23 Breathing Air Supply Completed
- To be in conformance with the provisions of 10 CFR 50.48 3-6 Issued by Supplement No. 2 to FPSER