ML18059A571
| ML18059A571 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/14/1993 |
| From: | Rogers D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9312210391 | |
| Download: ML18059A571 (3) | |
Text
'* p consumers Power POWERINli lllllCHlliAN'S PR.OliR.ESS Palisades Nuclear Plant:
27780 Blue Star Memorial Highway, Covert, Ml 49043 December 14, 1993 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 David W. Rogers Plant Safety and Licensing Director DOCKET 50-255 - LICENSE DPR PALISADES PLANT - FIRE PROTECTION -
CLARIFICATION OF INFORMATION CONCERNING THE CONTROL ROOM FIRE WALL RATING The purpose of this letter is to clarify the fire rating of the east wall of the control room and to initiate closure of this issue.
In our report submitted March 31, 1977, we identified the east wall of the control room as having a two hour fire rating. However, in another section of the report we incorrectly stated the east wall has a three hour fire rating. Analysis has been completed to show that the resultant two hour rating of the entire east wall does not decrease the post fire safe shutdown capability of the control room or the room adjacent to this area (ID switchgear room).
The following is the history of this issue in which previous correspondence described the east wall of the control room.
An NRC letter dated May 11, 1976 requested that a review of Palisades fire protection be performed per the guidelines of Standard Review Plan 9.5.1.
Subsequently on September 28, 1976, the NRC forwarded Appendix A to Branch Technical Position APSCSB 9.5-1 to Consumers Power Company (CPCo).
CPCo followed the guidance of Appendix A to Branch Technical Position 9.5-1 in developing our initial fire protection program.
The Appendix guidance also specified that a Fire Hazards Analysis (FHA) be performed for all areas of the plant and as a part of the FHA a determination be made as to fire barrier
- requirements.
On March 31, 1977, prior to the issuance of Appendix "R", the original FHA for the Palisades Plant was submitted to the NRC.
One portion of that analysis (Appendix I, Page VII-8, Fire Area 1) indicated the following fire barrier boundaries for the control room area: (1) the west wall has a three hour rating and provides access to the turbine building, (2) the north wall has a
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D A CMS' ENERGY COMPANY
Nuclear Regulatory Commission Palisades Plant Control Room Fire Wall Rating four hour fire rating and is a building wall separating the control room from the outside atmosphere, (3} the east wall has a two hour rating and separates the control room from a staircase which descends to the ID switchgear room, (4} the south wall is a three hour rated fire barrier and separates the control room from the auxiliary building corridor.
2 Another portion of that FHA described how the control room fire area was further divided into three fire zones with the designators A, B, and C.
These fire zones were then individually described.
It was in the description of Fire Zone C (Appendix I, Page VII-I5, Fire Area - Zone C) that a reporting error was made in describing the fire rating of the east wall of the control room.
Fire Zone C was described as the office and viewing area east of the control room with the east and*south walls having a minimum three hour fire rating.
The east wall should have been described as having a two hour fire rating.
Thus in the two portions of the original FHA noted above, the east wall of the control room was described as having both three and two hour fire rated walls.
On July I, I982, after issuance of IO CFR 50 Appendix R we applied for an exemption from the requirement of installing a fixed fire suppression system in the control room.
The exemption request did not request consideration of the two hour rating of the east wall of the control room.
On February 8, I983, the NRC granted the exemption determining that the installation of a fixed fire suppression system will not significantly increase the level of fire protection in the control room.
In part of the text of that exemption, the NRC made some general statements describing the control room.
One of the statements said that"... The control room is enclosed by walls, floor, and ceiling of reinforced concrete construction, sufficient to achieve a three hour rating." The NRC may have concluded that the control room was enclosed on all sides with three hour rated fire walls from the information provided in the original FHA analysis.
In March I992 during a general review of current Appendix R exemption requests, we recognized the incorrect statement, in the February 8, I983 exemption describing the east wall of the control room as having a three hour fire rating.. Further review identified that the error was due to our incorrect statement in our March 3I, I977 report. Subsequently, several discussions were held with the NRR Palisades Project Manager, however, we have not requested formal resolution of the issue.
We have determined that this situation does not impact the post fire safe shutdown of the plant as a consequence of a fire in either the control room or ID switchgear room fire areas because of the following:
Kuclear Regulatory Commission Palisades Plant 3
Control Room Fire Wall Rating (I) The ultimate post fire safe shutdown process for either room was and is the use of the alternate shutdown panel equipment.
When the original plant fire areas or zones were defined, the control room and the ID switchgear room, were defined as separate fire areas. Later reviews determined that a fire in either of these two areas would result in loss of instrumentation such that plant shutdown would be completed using the auxiliary shutdown panel in the south electrical penetration room.
Thus, in effect, a fire in the ID switchgear room would have the same ultimate effect as a fire in the control room, and essentially these two rooms can be considered in the same fire area.
(2) An evaluation has been performed which demonstrates that the two hour portion of the wall does not degrade the fire separation rationale used to classify the control room and the ID switchgear room as separate fire areas.
(3) The justification we submitted in our July I, I982 request for exemption from a fixed fire protection system for the control room does not request that credit for the three hour fire barrier protection of the control room be one of the factors considered when evaluating the exemption request.
(4) Although the NRC exemption request dated February 8, I983 describes the control room as being enclosed by walls sufficient to achieve a three hour fire rating, the reason given for granting the exemption is
"... because the fire hazard is light, the control room is continuously manned, and fire extinguishing equipment is located in the cotitrol room."
We believe that the fire rating of the east wall of the control room was not a deciding factor in the NRC's decision to approve the exemption for automatic fire suppression system in the control room.
Corrections have been made to our fire protection program documents to assure that the east wall of the control room is described as being a two hour fire barrier.
Your review of this situation is requested.
If any additional action on our part is required please advise.
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David W. Rogers Plant Safety and Licensing Director CC: Administrator Region III, USNRC Resident Inspector Palisades