ML20155F601

Responds to Request for Addl Info Re Insp of Fire Protection Measures & Compliance w/10CFR50.48 & App R.Corrective Actions from 851209-13 & 860305 Insp Summarized

ML20155F601
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	04/14/1986
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8604220276
Download: ML20155F601 (7)

Text

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@M SMM M' Consumers POW 8f Generet Offees: 1945 West Pamall Road, Jackson, MI 49201 (517) 788-1636 x.nn.m w s.ny Durctor Nwirar Ekenung April 14, 1986 Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLAh -

FIRE PROTECTION - ADDITIONAL INFORMATION REGARDING ITEMS OF NON-COMPLIANCE /0 PEN ITEMS IDENTIFIED DURING 1985/1986 INSPECTION An inspection of fire protection measures and compliance with the applicable sections of 10CFR50.48 and 10CFR50, Appendix R was conducted by the NRC at the Big Rock Point Plant from December 9, 1985 through December 13, 1985. This inspection was continued during the week of March 5, 1986. Certain items of non-compliance with the applicable regulations and a number of open items were identified by the NRC inspectors during this inspection. A meeting with the NRC inspectors and representatives of the NRC-NRR was then held in Washington, DC on March 31, 1986 to discuss these items. During this meeting, Consumers Power Company agreed to submit a letter within 14 days which responds to the following NRC requests:

1. Identify all areas in the Plant which are not in compliance with applicable sections of 10CFR50.48 and 10CFR50, Appendix R, or areas which are not in compliance with regulations because an exemption has not been requested.

2. Describe the compensatory actions taken for the items identified in response to "1" above.

3. Provide a date for submittal of a comprehensive fire protection summary document to the NRC. (This summary document should include an updated Fire Hazards Summary, Safe Shutdown Summary, all pertinent correspondence between the NRC and Consumers Power Company concerning compliance to 10CFR50.48 and 10CFR50,  !

Appendix R, as well as Appendix A to Branch Technical Position  !

(BTP) 9.5-1.) l l

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Director, Nuclear Reactor Regulation 2 Big Rock Point Plant Fire Protection-Items on Non-Compliance April 14, 1986 This letter provides the responses to these requests, and summarizes Consumers Power Company's plan for resolving the items identified in the responses to "1". This letter includes, for completeness, the information in our letter dated March 14, 1986 which described the compensatory actions taken for the lack of emergency lighting in the Plant yard and the indeterminate temperature rise due to an oil fire in the Recirculation Pump Room.

The following four items of non-compliance / lack of exemption request have been identified.

A. 10CFR50, Appendix R, section III.J and 10CFR50, Appendix B -

Untimely Corrective Action - Corrective action to resolve deficiencies with emergency lights within the power block was not taken in a timely manner.

B. Routine fire protection measures - Lack of Control of Combustibles - Combustible material was stored in the vicinity of the electrical conduits carrying electrical cable for the Alternate Shutdown Building.

C. 10CFR50, Appendix R, section III.J - Lack of Emergency Lighting in Yard - Plant yard lighting that illuminates access and egress to areas / buildings in which safe shutdown equipment is located is not powered by an emergency power source.

D. 10CFR50, Appendix R, section III.G.2 - Lack of Exemption Request for Screenhouse - A radiant energy shield was installed in the Screenhouse, in lieu of fixed suppression, to protect the service water pumps in the event of a fire which disabled the diesel fire pump located in the same building. While this compensatory measure was approved by the NRC in its review of our response to BTP9.5-1, Appendix A, an exemption to the requirements of 10CFR50, Appendix R, section III.G.2.b which applies to fixed suppression in areas of redundant equipment was not requested.

The following open items have also been identified.

E. Unresolved exemption request concerning the separation of safe shutdown circuits in the Control Room.

F. Unresolved exemption request concerning the need for oil collection capability in the Recirculation Pump Room.

Each item is discussed below.

A.I. Untimely Corrective Action During the inspection, two of four emergency lights tested failed to operate for eight hours. Although a duration problem was identified by Consumers Power Company in August, 1984, corrective OC0486-0072-NLO4 J

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Director, Nuclear Reactor Regulation 3 Big Rock Point Plant Fire Protection-Items on Non-Compliance April 14, 1986 action was incomplete at the time of the inspection in December, 1985. This is considered to be an isolated incident.

2. Compensatory Actions A sufficient number of portable battery powered lanterns have been made readily available to the Plant operators, and will remain available until the corrective action described below is completed.

Plan for Resolution A modification will be made to the emergency lighting units that were installed as required by 10CFR50, Appendix R, section III.J.

to increase the capacity of these units. This modification involves adding an additional battery of the same ampere-hour capacity in parallel to the existing battery, thereby effectively increasing the time rating on each unit to greater than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

This modification will be completed by September 1, 1986.

B.1. Lack of Control of Combustibles During the December, 1985 inspection, resin-filled barrels temporarily located in the Turbine Building in the vicinity of the electrical conduits associated with the Alternate Shutdown Building were identified by the inspectors. Contrary to Consumers Power Company's determination, the NRC inspectors confirmed that this material is flammable and therefore constitutes a potential fire hazard. This is considered an isolated incident.

2. Compensatory Actions The barrels were relocated to an appropriate storage area upon identification of the concern by the NRC inspectors.

Plan for Resolution To prevent the recurrence of improperly stored combustibles that would contribute to the fire loadings in any fire area, the Plant staff has been reminded to be more aware of transient fire loads and has been directed to remove or clean up such materials as soon as ongoing work activities are completed. The Plant Property Protection Department will conduct routine naspections of the Plant to assure compliance. The Plant is ns. in compliance with requirements, and no further actione are deemed necessary.

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c y-Director, Nuclear Reactor Regulation 4 Big Rock Point Plant Fire Protection-Items on Non-Compliance April 14, 1986 C.I. Lack of Emergency Lighting in Yard Access and egress to/from buildings / locations outside the power block are necessary in order to operate equipment needed for safe shutdown (eg, Screenhouse, Alternate Shutdown Building, Stand-by Diesel Generator). Lighting in the Plant yard area along routes to these buildings / locations is not powered by an emergency power source, or is nonexistent. The decision not to provide emergency lighting in the yard area was based on Consumers Power Company's determination that such lighting was unnecessary for Plant operators to access / egress the safe shutdown equipment outside the power block.

2. Compensatory Actions As committed to in our letter dated March 14, 1986, a sufficient number of portable battery powered lanterns have been made readily available to the Plant operators.

Plans for Resolution An exemption from the applicable requirements of 10CRF50, Appendix R, section III.J will be requested. This request for exemption will be based on an appropriate justification and will be submitted to the NRC by May 1, 1986.

D.1. Lack of Exemption Request for Screenhouse As a result of the NRC's review of our " Fire Protection Program Evaluation," dated March 29, 1977, the NRC stated its position in a ' letter dated November 20, 1978 that either a sheet metal shield or a sprinkler system installed in the area of the diesel fire pump would protect the redundant fire and service water pumps from a fire at the diesel fire pump. By letter dated December 8, 1978, Consumers Power Company committed to the installation of a sheet metal (radiant energy) shield in the area of the diesel fire pump, and its installation was verified during the 1985/1986 inspection. NRC Generic Letter 81-12 (" Fire Protection Rule,"

dated February 20, 1981), however, clarixied the requirement to reexamine fire protection measures for ccmpliance with 10CFR5J.48 and 10CFR50, Appendix R even if these measures were approved by Safety Evaluation Reports previously issued by the NRC. Although Consumers Power Company had acknowledged receipt of Generic Letter 81-12, an exemption from the requirements of 10CFR50, Appendix R, section III.G.2.b regarding fixed suppression in the screenhouse was not requested. This omission is considered an oversight.

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r Director, Nuclear Reactor Regulation 5 Big Rock Point Plant Fire Protection-Items on Non-Compliance April 14, 1986

2. Compensatory Action Plant operations personnel tour this area every two hours, and security personnel now tour this area every four hours. (Note that the four-hour tour by security personnel will now be required until this issue is resolved.) Both operations and security personnel are qualified as members of the Plant fire brigade. The Screenhouse also contains four rate-of-rise heat detectors that alarm in the Control Room. The manual suppression equipment that is maintained and available in the Screenhouse includes a hose reel, a 150 lb. wheeled dry chemical ANSUL cart extinguisher. :wo 30 lb. portable dry chemical extinguishers, and a 20 lb. port ble carbon dioxide extinguisher. Consumers Power Company considers that these fire protection measures provide adequate assurance that detection of and response to a fire in the Screenhouse will be accomplished rapidly, and most probably before any danage occurs.

Plan for Resolution An exemption from the requirements of 10CFR50, Appendix R, L

< section III.G.2 will be requested. This request for exemption will be based on an appropriate justification and will be i submitted'to the NRC by May 1, 1986.

E.1. Unresolved exemption request concerning the separation of safe shutdown circuits in the Control Room As a result of the 1985/1986 inspection, our understandings of the status of the exemption submitted by Consumers Power Company by letter dated September 28, 1982, is that this request is unresolved, ie, neither approved nor disapproved. This exemption concerns the separation of the emergency condenser inlet valve circuits, core spray valve circuits, and the reactor depressurization system circuits in the Control Room. Since this

. exemption request is unresolved, Consumers Power Company agrees i that compensatory actions must be identified.

2. Compensatory Actions A Control Room " fire watch" will be implemented by personnel other than the Control Room operators performing a tour of the Control Room approximately every 20 minutes. This action will

remain in effect until this item is resolved. Although we commit to implementing this " fire watch", we also point out that the Control Room is continuously manned by Plant operations personnel trained and equipped to fight fires in the Control Room.

Automatic Products of Combustion detectors are installed and  ;

alarm in the Control Room. Two portable carbon dioxide

extinguishers and three self-contained breathing units are maintained and available in the Control Room. In addition, two OC0486-0072-NLO4

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Director, Nuclear Reactor Regulation 6 Big Rock Point Plant Fire Protection-Items on Non-Compliance April 14, 1986 2-3 gallon water extinguishers and a standpipe with 50 feet of 1-) inch hose and 50 feet of extra hose are located just outside the Control Room door.

Plan for Resolution Additional clarifying information is currently being assembled to support the exemption requested on September 28, 1982. This information will be submitted by June 1, 1986.

F.1. Unresolved exonption request concerning the need for oil collection capability in the Recirculation Pump Room.

By letter dated February 9, 1982, Consumers Power Company requested an exemption from the requirements of 10CFR50, Appendix R, section III.0 for the Recirculation Pump Room. This request included a calculation of the temperature rise in this Room due to an oil fire as supporting justification for the exemption. This calculation was found to be in error by the NRC-Region III, and was discussed with the NRC inspectors during the March, 1986 inspection. (Note: Our March 14, 1986 letter erroneously stated that calculation error was identified by Consumers Power Company due to a misunderstanding.) Accordingly, the expected maximum temperature in the Recirculation Pump Room due to an oil fire is now uncertain, thereby changing the status of this exemption to unresolved.

2. Compensatory Action As described in our letter dated March 14, 1986, an Operations Memo has been issued to all Plant operators emphasizing the importance of activating the Recirculation Pump Room sprinklers upon receipt of an alarm from any of the detectors in this Room (in conformance with Big Rock Point Plant Alarm Procedures ALP 1.6). This actuation involves opening the sprinkler head supply valve via a hand switch located in the Control Room. The sprinkler heads are the fusible link type and are designed to open at 250*F.

Plan for Resolution The calculation of the temperature rise in the Retirculacion Pump Room due to an oil fire has been re-performed, and is currently '

being checked by an independent technical reviewer. Based on the final result of this recalculation, appropriate corrective action, if any, will be identified and submitted to the NRC by June 1, 1986. If the recalculation results in a Room temperature rise that supports the original exemption request, the corrected calculation will be submitted to the NRC for review and approval by May 1, 1986.

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~ . -g Director, Nuclear Reactor Regulation 7 Big Rock Point Plant Fire Protection-Items on Non-Compliance April 14, 1986

3. Comprehensive Fire Protection Summary Document for the Big Rock Point Plant.

A comprehensive fire protection summary document will be submitted to the NRC before startup from the upcoming refueling outage (startup is currently planned for Dece:aber,1986). This summary will include an updated Fire Hazards Analysis and tabulation of the bases and assumptions which support the Analysis, all pertinent documentation and/or an index of fire protection documents (eg, correspondence between Consumers Power Company and the NRC, procedures, surveillances, training programs), the Safe Shutdown Summary, and revised plant system descriptions which describe fire protection equipment.

Kenneth W Berry Director, Nuclear Licensing CC- Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point OC0486-0072-NLO4