ML20044A984

Updates 881207 Response to Open Items Noted in Insp Rept 50-155/88-06.Corrective Actions:App R Schemes Completed on 890113.Requirements of App R,Section III.G.3 Satisfied for Fire Areas 12 & 13 & Associated Boundaries

ML20044A984
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	07/13/1990
From:	Eddy J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9007170125
Download: ML20044A984 (5)

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oeneral offices: 212 We,t Machigan Avenue, Jackson, MI 40201 * (617) 788 0550 W

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\\R' DOCKET 50-155 - LICENSE DPR-6. BIG ROCK POINT PLANT'-

[n' STATUS,

SUMMARY

FOR NRC INSPECTION REPORT 88-006'OPEN ITEMS 4

-(UPDATE TO. DECEMBER.7.'1988 LETTER);

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NRC-Inspection R'eport 88-006 identified no violations,of NRC requirements.but1 (didicontain several open or unresolved items. - NRC letter dated May 18,<1988 l

transmitted the Inspection Report and requested that'certain items he specif1-~

cally: addressed.,

.Following discussions with Mr. Joe Ulie of USNRC, Region III, this letter.

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'provides a status update.'of Consumers Power Company. actions'with ' respect to i

7 those items, and'specifically addresses unresolved items88-006 -02 and 88-006-03,'as requested.

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OPEN VIOLATION 155/85-022-03 lD

"The!11cennee. failed to requestJan exemption from the requirements of l

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'Section'III.G'.2 of /.ppendix R after determining-that the fire protection.

.ments of-'Section III.G.2, in'that no fire suppression system was; installed.".

1 1 features in the Screenwell' and Pumphouse did.not meet the specific require-l Status.

n The' exemption was received on February 8, 1990.

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1 0 PEN ITEM 155/85-022-11 t

' 'As discussed ~on page nine of.the-May-18, 1988 Inspection Report, the-inspectors felt that a more detailed. electrical analysis section relative:co j

V sAppendix'R was needed'and further update of the Fire Protection Plan' Summary j

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A complete coordination study of the Appendix R schemes was completed on

January 13,1989;

• Mr. David Buthr of USNRC Region III has performed a review

.of this' analysis as part of.:a fallow-up on Big Rock Point LER 89-01 submitted-q NM4y O ;

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' Status Summary Inspection Report 88-006-1 cJuly-13, 1990 3

on February 20,11989. This evaluation was incorporated into Section 11 of the_

FPPSD by xoference on March 30, 1990.-

UNRESOLVED ITEMS 155/88-006-01, 02,-03

During the follow-up Region III Appendix R Inspection during March., 1988 at Big Rock Point (BRP) an issue was discussed with respect to compliance with

,III.G for three specific locations and the inspection repot' requests that a submittal be provided for NRR review. Those locations ar;.

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Third floor of Administrative Building (88-006-02)

RDS/ Compute. Room (88-006-03) b 2.. : Zone adjacent to the inside Cable Penetration Area (88-006-01) 3.

Status The following provides a discussion of Consumers Power's position with respect

.to these concerns'.

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Arpendix R. III.G.1-requires that hot shutdown c.ystems must be procected from postulated fires in order to maintain one train " free of fire damage."

Appendix R, III.G.2.provides circuit separation criteria-for meeting III.G.1

. achieve and maintain hot shutdown) when redundant trains or systems are

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located within-the same fire area. Appendix R, III.G.3' compliance is for cases where III.G.2 criteria cannot be met.

With regard to items 155/88006-02 and 03, the following clarification information shows that redundant circuits are not located within the same fire area but.are separated by fire aren

' barriers irt accordance with Generic Letter 86-10' guidance.

1 Generic Letter 86-10 provides the essential guidance for understanding and:

implementing Section III.G of Appendix R with-respect to Fire Area Boundaries-and Automatic Detection and Suppression, as follows:

Fire Area Boundaries-u

....an area sufficiently bounded to withstand the hazards associated with-the area, as.necessary,-to protect important equipment within the area

from a fire outside the area.

.... licensees must perform an evaluation to assess the adequacy of fire boundaries in their plant to' determine if the boundarios will withstand the hazards associated with the area.

Automatic Detection and Suppression In-order to comply with these provisione, suppression and detection

. sufficient to protect against the hazardi of the area must be installed.

-In this regard, detection and soepression providing less than full area coverage may be~ adequate for compliance, providing licensees perform-an-evaluation to assess the adequacy of partial suppression atui detection to

. protect against the hazardsuin the area.. An exemption must be requested when a licensee is providing no suppression or detection.

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. Status Summary - Inspection _ Report 88-006 July:13, 1990-r The Big Rock Point Fire Hazards _ Analysis documents fire areas.and.their associated boundaries. Based upon these areas and boundaries. if redundant

_ safe' shutdown systems are shown to be adequately separated by fire area

. boundary barriers,-then the requirements of III.G.2 are met thereby satisfying the requirements;of III.G.1, without the need for installation of additional-separation / barriers, detection or suppression.

This is the case for-the third 1

floor of the Administrative Building and the pDS/ Computer Room.

Third Floor of the' Administrative Building (88006-02)

TheJBRP Fire Hazards Analysis for Fire Area 12 which includes the third floor of the Administrative Building shows that only one set of alternate shutdown circuits pass through this area. These circuits operate the emergency.

condenser valves and can ie isolated from the area by transfer switches not

-located in the area. All other: shutdown circuits or equipment are located in other fire areas, thus as discussed earlier,111.C.2 it. satisfied be.:ause -

redundant. trains or circuits necessary for hot shutdowt 6do not exist.in this area. The adjacent fire area containing shutdown circutta is the control room. The south wall of the control room is less than three hour rated, hov 4r, analysis (page C-11 of the BRP Fire Protection Provisions Reflects)

-dete: nined-the wall to be adequate due to the very light exposure. This is consistent with the guidance of Generic Letter 86-10 (Question 3.1-2, page 4),

which addresses " fire area" as an area sufficiently bounded to withstand the

-hazards associated with the area and, as necessary, to protect important.

equipment within the fire area from a fire outside the area. The analysis conclusion is:further supported by the NRC Safety Evaluation associated with Amendment 25,' dated' April 4, 1979 which accepted the south wall of the control room as a fire area barrier, as stated below:

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" Substantial fire barriers have been provided throaghout the plant. The licensee's fire hazards analysis indicates that the basic wall, floor and ceiling structures bounding each fire area have adequate fire resistance to prevent the spread of an unsuppressed fire through.the barriers.

Barriers not having a 3-hour fire resi.cance rating are considered acceptable on the basis of the light combustible loading, or on the basis

,that safe shutdown capability will not be jeopardized if the barrier is fb r e ach ed'.'"

Generic Letter 86-10 states that, " Boundaries described in the Appendix A Fire

' Hazards Analysis, and evaluated and accepted in a published SER, need not be

reviewed as part of the re-analysis for compliance with Section III.G of-Appendix R."

RDS/ Computer Room (88006-03) y

.The BRP Fire Hazards Analysis for Fire Area 13. RDS/ Computer Room, shows that only the.RDS actuation / sensor cabinets and associated cabling are located in Lthis area. These circuits operate the reactor depressurtzation valves used to

' lower reactor pressure to enable the core spray system to provide flow to the reactor. This method of shutdown is redundant to the emergency condenser method. However, shutdown circuits and equipment for the emergency condenser Oc 'OC0690-0221A-NLO4 F

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Nuci d r Rigulctory Commission-4 Big' Rock Point _ Plant'

' y' Status Summary,- Inspection Report 88-006

' July 13, 1990;-

Emethod are not located in this fire area, thus III.G.2 is satisfied for this fire area. Once again, redundant trains or circuits necessary for hot shut-r k,

down~do'not exist in Fire Area 13.

In conformance with the Guidelines of

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Generic letter'86-10, the barriers for this fire area were deterrtined by analysis to be adequate due to the-fire loading in the area.

. Conclusion

'The discussion above shows that the requirements of III.G.2 are satisfied for

Fire Areas 12 and 13 and the associated boundaries located between Fire Areas-112

and 1, and Fire Areas 13 and 5, concluding that the existing detection and suppression capabilities described in the BRP Fire Hazards Analysis, are

. adequate for the_ areas.-

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However, further review has cencluded_that a spurious signal caused by a fire t

~in Aten 12 could cause a malfunction of the Emergency Condenser (EC) Outlet g

V,alve Control from the Control Room. This f ailure (valve closure) would occur after initial actuation since the outlet valves automatically open on a loss

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_of offsite, power.

If this unlikely event were to. occur, the plant could he'

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safely shutdown by reopening the EC outlet valves from the ~niternate shutdown i

' building or from the Control Room using Method II - RDS Core Spray. Even though failure is unlikely due to small amount of cable'and close proximity to

'the Control Room where prompt fire brigade response-can be initiated, improve-

.ments,will be made:to increase fire integrity of these circuits. These-actions.were completed during the 1989 Refueling Outage.

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Zone Adjacent to the Inside Cable Penetration Room (88006-01) l I

In discussing: fire areas and zones in containment >and their classification as y

III.G 2 and III.G.3, a concern was raised regarding separation and barriers between Zone A and B of Fire Area 11.

This in turn reflects on provisions (suppression and detection) needed in these areas to' insure.that one~ train of

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= shutdown systems is maintained free of fire damage.

Specifically the question raised was, r_ince Zone'A is classified as a'III.G.3 zone needing fire detection, then Zone B should have detection'since finite-barriers do not

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exist between the zones.

Fire detection and suppression needs for containment have been reviewed ~and discussed.in various'submittals dating back to 1977 when the~ initial Fire.

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Hazards Analysis was completed for BRP. It was recognized at that time that 100%ifire detection and suppression coverage was not practical for BRP.

containment.- In' our submittal dated September 28, 1982, Attachment D, exemption request item 4, compliance with Appendix'R Section III.G.3 for 1

containment is discussed. The exemption request from fixed fire suppression.

discusses the' fire detection systems proposed for containment to insure prompt identification'and actions. These reflect the provisions approved by the NRC in their_ Safety Evaluation Report dated April 4, 1979 which specifically l

o identifies that detection systems are only needed for '.he following areas in containment in meeting III.G.3:

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'InteriorLCable Penetration Area Control Rod-Drive Accumulator Aren-Shutdown Heat Exchanger Room l

In a letter dated March 8, 1983, the NRC granted the above exemption from

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III.G.3.

The Safety Evaluation associated with the' exemption recognizes the low fire load in containment, detection capability described above, distribu-tion of' fire hose stations in containment, and concludes that this level of f

protection in conjunction with the-proposed alternate shutdown capability will provide a level of fire protection equivalent to the technical requirements.of Section III.0 of Appendix R.

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f Consumers Power maintains that-the NRC Safety Evaluation contained in t a April 4, 1979 and March 8, 1983 letters adequately documents BRP compli ce with Section III.G'of Appendix R.

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i Summary Consumers Power believes that the above discussion eutlines the basis wh'ere 1

compliance to Section III.G of Appendix R has been established for the areas of concern identified during the 1988 Inspection.

In a follow-up conversation' with Mr. J Ulie'on April 19, 1988 an additional: concern was raised with respect;to lack of_a documented evaluation for detection adequacy _in Fire Area-

11, Zone B.

This may have_just been an oversight during the inspection.

In, j

addition to'the NRC evaluations contained in the April 4, 1979 and March 8, 1983 letters,. Appendix C of Fire Protection Features-Summary Document trans-

-mitted to NRC on February 27. 1987 and reviewed'onsite'during the inspection provides.an evaluation of containment fire detection. This section explicitly

' discusses the lack of detection for this area of concern.

It-is also important to point out that for a11'three of the area's at issue the-inspectors did' conclude =that " alternate.slatdown capability does exist. With s

the alternate method.available, fire damage could occur'to cquipment in these

' locations; however, one train of system free of fire damage wo.uld still'be.

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available to achieve and maintain hot shutdown conditions from the Alternate Shutdown Building. Therefore, the safe shutdown capability of Section III.G.l'

-was met."

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J Daniel' Eddy

, Plant-Licensing Engineer a

CC Administrator, Region III, USNRC

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NRC Resident Inspector - Big Rock Point 1

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