ML20206T365

Forwards Request for Exemption from 10CFR50,App R, Fire Protection Program, Sections Iii.J, Emergency Lighting & III.G.2.b, Fire Protection of Safe Shutdown Capability, Per Results of 851209 & 860305 Insps & Meetings.Fee Paid

ML20206T365
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	07/01/1986
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8607080098
Download: ML20206T365 (6)

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@ CORSum8IS mammans ruesness Power m,%

h a lkensing l

General Offices: 1945 West Pernell Road. Jackson, MI 49201 e (517) 788-1636 July 1, 1986.

Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

FIRE PROTECTION - REQUESTS FOR EXEMPTION FROM CERTAIN PROVISIONS OF 10CFR50, APPENDIX R, " FIRE PROTECTION PROGRAM FOR NUCLEAR POWER FACILITIES OPERATING PRIOR TO JANUARY 1, 1979" Consumers Power Company letter dated May 30, 1986 committed to submit by July 1, 1986, requests for exemption from certain provisions of 10CFR50, Appendix R. Specifically, exemptions from 1) Appendix R, section III.J.

" Emergency lighting" for emergency lighting in the Plant yard area and standby diesel generator, and 2) Appendix R, section III.G.2.b, " Fire protection of safe shutdown capability" for the lack of fixed suppression in the Screen-house, are requested. The need to request these exemptions was identified as a result of the NRC fire protection inspection conducted at the Big Rock Point Plant. This inspection took place during the weeks'of' December 9, 1985 and March 5, 1986, and associated meetings were held between Consumers Power Company and the NRC on March 31, 1986 and May 8, 1986. Accordingly, the requests for exemption, in accordance with the provisions of 10CFR50.12, are provided in Attachment 1.

A check in the amount of $150.00. (approval fee) is enclosed in accordance with 10CFR170.12(c).

fbNdbg Kenneth W Berry Director, Nuclear Licensing CC' Administrator, Region III, USNRC-NRC Resident Inspector - Big Rock Point t [..

Attachments 8607080098 860701 I /,

OC0686-0101-NLO4 PDR ADOCK 05000155 W MK- 1 F PDRg gg i

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ATTACHMENT 1 Consumers Power Company Big Rock Point Plant Docket 50-155 j REQUESTS FOR EXEMPTIONS ~

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FROM CERTAIN PROVISIONS OF 10CFR50, APPENDIX R

July 1, 1986 4

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, BIG ROCK POINT PLANT EXEMPTION REQUEST EMERGENCY LIGHTING IN PLANT YARD AREA AND STAND-BY DIESEL GENERATOR i

i Section III.J of Appendix R to 10CFR50 requires that emergency lighting units i with at least an 8-hour battery power supply be provided in all areas needed i for operation of safe shutdown equipment and in the access and egress routes i thereto.

1 To safely shutdown the Big Rock Point Plant in the event of certain postulated

]- fire scenerios, operators would need to leave the contiguous Service Building,

. Turbine Building and Containment (ie, power block) and travel to the Alternate j Shutdown Building (ASB), the Screenhouse, the Emergency Diesel Generator Building, and/or the stand-by diesel generator. Emergency lighting with at least an 8-hour battery supply has been installed along access and egress routes to and from safe shutdown equipment within the power block, as well as for operation of this equipment and. equipment in the ASB, Emergency Diesel Generator Building, and the Screenhouse. Emergency lighting to access and egress the safe shutdown equipment outside the power block, and for operation

, of the stand-by diesel generator, has not, however, been installed.

i j For the following reasons, Consumers Power Company has determined that the use of portable battery powered lanterns is equivalent, and therefore is an acceptable alternative, to the installation of permanent 8-hour emergency lighting in the Plant yard area and stand-by diesel generator as' required by 10CFR50, Appendix R, section III.J.

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a. Emergency lighting of the Plant yard area is needed for short J. periods of time to allow travel to and from safe shutdown equipment; f no longer than five minutes of lighting per occurrence is necessary

for access to and egress from the ASB, Screenhouse, and. Emergency

} Diesel Generator Building.' No longer than 15 minutes of lighting

per occurrence is needed-to access,' start, and egress the stand-by i diesel generator.

, b. A sufficient number of portable lanterns are maintained in or near i

the Control Room to assure adequate lighting is available to opera-

tors during an 8-hour period for the purpose of shutting down the Plant.during periods-of darkness.

. b. The use of portable lanterns to illuminate Plant yard areas affords i more flexibility than permanently installed emergency lighting since the lanterns can illuminate alternate route of access / egress if the need arises.

c. The ability of an operator to start and operate the stand-by diesel i

generator using a portable lantern for light'will be demonstrated' I

before startup from the next refueling outage.

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2 Accordingly, Consumers Power Company requests an exemption from the require-ments of 10CFR50, Appendix R, section III.J for the Plant yard area and stand-by diesel generator. This exemption request satisfies the provision of 10CFR50. (1)(ii) in that we have shown that application of the emergency lighting regulation is not necessary to achieve the underlying purpose of the fire protection rule so long as portable lanterns are maintained available and are used by operators when necessary to safely shut down the Plant.

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I BIG ROCK POINI PLANT EXEMPTION REQUEST t

FIXED FIRE SUPPRESSION SYSTEM l IN THE PLANT SCREENHOUSE

Section III.G.2.b of Appendix R to 10CFR50 requires that redundant trains of equipment necessary to achieve and maintain hot shutdown conditions be sepa-rated by more than 20 feet of horizontal distance, with no intervening combus-tible or fire hazards, and that fire detectors and an automatic fire suppression system shall be installed in the area. The Plant Screenhouse f

houses the diesel fire pump and the two service water pumps. These pumps are considered redundant with regard to achieving and maintaining cold shutdown conditions.

The existing physical configuration of safe shutdown equipment in the Screen-house is compared to the criteria of 10CFR50, Appendix R, section III.G.2.b as follows.

I III.G.2.b - Separation by a horizontal distance of more than 20 feet with j no intervening combustible or fire hazards.

l Screenhouse - The diesel fire-pump is separated from the service water pumps by a horizontal distance of 21 feet, and there are no interven-ing combustible or fire hazards.

l III.G.2.b - Fire detectors and an automatic fire suppression system shall be installed in the fire area.

Screenhouse - Fire detectors are installed in the Screenhouse and alarm in l the Control Room. Automatic fire suppression is not installed in this area since a fire in the Screenhouse which renders both the diesel and electric fire pumps inoperable would remove the source of water for the Screenhouse sprinklers, thereby defeat-ing the purpose of the suppression system. The absence of fixed suppression in the Screenhouse was identified in the Big i Rock Point " Fire Protection Program Evaluation," which was submitted to the NRC by letter dated March 29, 1977. In its review of this Program Evaluation, the NRC stated its position in a letter dated November 20, 1978 that either a sheet metal i

shield or a sprinkler system installed in the area of the diesel fire pump would protect the service water pumps from a i fire at the diesel fire pump. Since the installation of sprinklers would not be capable of functioning as a suppression system in the event of a fire which damages the diesel and electric fire pumps, as explained above, a radiant energy I shield was installed instead.

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NRC Generic Letter 81-12 explained-that licensees are required to reexamine fire protection measures for compliance with 10CFR50.48 and 10CFR50, Appendix R, even if these measures were previously approved by the NRC.

Therefore, an exemption from 10CFR50, Appendix R, section llI.G.2.b is neces-sary due to the absence of a suppression system in the Screenhouse. Consumers Power Company has determined that such an exemption is appropriate based on i the following justification.

Consumers Power Company considers that the existing fire protection measures delineated above would limit damage to either the diesel (and possibly the i electric) fire pump or the service water pumps in the event of a fire in the

Screenhouse. Therefore the undamaged pump (s) would be available to safely shut down the Plant as summarized in our letter of March 21, 1986. While

{ Consumers Power Company has concluded that a fire in the Screenhouse would not 1

render both the diesel fire pump and the service water pumps inoperable and beyond repair using onsite capability, we have evaluated the ability to safely shut down the Plant without the use of these pumps. Consumers Power Company has determined, as described below, that the Plant can be taken to hot shut-f down conditions without using the diesel fire pump or service water pumps, and cold shutdown can be achieved and maintained by using a fire truck to supply lake water to the Fire Water System.

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The water inventory maintained in the shell of the emergency condenser (EC) is

adequate for the Plant to achieve and maintain hot shutdown conditions for l four hours after a reactor trip occurs due to a fire in the Screenhouse and j loss of off-site power. Make-up to the EC shell, which could be provided by

the diesel fire pump, and a heat sink for the shutdown cooling system provided-l by the Service Water System, are not required during this four hour period.

j Therefore, neither the diesel fire pump nor the service water pumps are needed j during this period. To achieve cold shutdown, a fire truck (pumper) would be

called to the site by procedure and,' drafting from Lake Michigan, would begin pumping water into the fire system within four hours. The. fire system is then connected to the service water system, and cooling to cold shutdown via the i shutdown cooling system can be initiated once the primary system pressure is below 300 psia. Makeup to the EC shell could be provided at any time by the demineralized water pump.

i Therefore, if a fire occurs in the Screenhouse, and fire-induced damage is

limited to either the diesel fire pump or the service water pumps, the Plant would be safely shutdown by the methods described in Consumers Power Company j letter dated March 21, 1986. Should the diesel fire pump and service. water i

pumps become inoperable and unrepairable, the Plant could be safely shutdown using the methods described above, ie, using the initial EC shell inventory to achieve hot shutdown and a fire truck to achieve cold shutdown. Accordingly, Consumers Power Company requests an exemption from the requirements of 10CFR50, Appendix R, section III.G.2.b for a fixed fire suppression system in the Screenhouse. This exemption request satisfies the provisions of 10CFR50.12(a)(ii) in that we- have shown that application of the fixed suppres-sion regulation is not necessary to achieve the underlying purpose of the fire protection rule since ,the Plant can be safely shutdown in the event that a .

Screenhouse fire renders both the diesel fire pump and the service water pumps inoperable and unrepairable.

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