IR 05000255/1986022
| ML18052A995 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/04/1987 |
| From: | Harrison J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Buckman F CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| NUDOCS 8705110155 | |
| Download: ML18052A995 (5) | |
Text
Docket No. 50-255 Consumers Power Company ATTN:
Dr. F. W. Buckman Vice President Nuclear Operations 212 West Michigan Avenue Jackson, MI 49201 Gentlemen:
MAY 4 1987 Thank you for your letter dated December 12, 1986, informing us of the steps you have taken to correct the noncompliance which we brought to your attention
. in Inspection Report No. 50-255/86022 forwarded by our letter dated November 14, 198 Regarding your response to Item 1 of the Notice of Violation, we have reviewed the information in your response and still believe this is an example of noncom-plianc We disagree with your position that paragraph 3.E of Provisional Operating License DPR-20 refers only to cable conduit seals located at the Battery Rooms and at the Southwest Penetration Roo In addition, it remains our position that the installed Junction Box/Pull Box, for which a technical analysis was not completed at the time of the inspection, failed to comply to the applicable criteria. However, based on the corrective actions identified in your response no further response to this item of noncompliance is require We will review these actions in a future inspection *
Your cooperation with us is appreciate cc: Mr. Kenneth W. Berry, Director Nuclear Licensing J. F. Firlit, General Manager cc w/ltr dtd 12/12/86:
DCS/RSB (RIDS)
Licensing Fee Management Branch Resident Inspector, RIII
- Ronald Callen, Michigan Public Service Commission Nuclear Facilities and Environmental Monitoring Section
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Sincerely, Origina1 Signad by J. J. Harrison J. J. Harrison, Chief Engineering Branch R~
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consumers Power l'OWERINli JIA.ICHlliAN'S PROliRESS General Offices:
1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-1636 December 12, 198 James G Keppler, Administrator Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-255 - LICENSE DPR-20 - PALISADES PLANT -
RESPONSE TO IE INSPECTION REPORT 50-255/86022 (DRS)
FIRE PROTECTION
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Kenneth W Berry Director Nuclear licensing Two items of noncompliance were identified in Fire Protection Program Inspection Report 50-255/86022 (DRS).
This letter provides Consumers Power Company's response to the two noncompliances identified as Item 1 and Item 2 in the Notice of Violation enclosed with the Inspection Repor ITEM 1 (NONCOMPLIANCE 255/86022-05)
Provisional Operating License No. DPR-20 paragraph 3.E states "The licensee may proceed with and is required to complete the modifications identified in paragraph 3.1.1 through 3.1.23 of the NRC's Fire Protection Safety Evaluation on the facility dated September 1, 197 These modifications shall be completed as specified in Table 3.1 of the Safety Evaluation in accordance with the schedule contained therein." These required modifications include sealing conduits that penetrate fire rated wall The Safety Evaluation dated September 1,. 1978, Section 3. entitled "Conduit and Ductwork Penetrations and Unprotected Openings" states "conduit penetrations of fire walls, floors and ceilings, which are not already sealed will be sealed both between the conduit and the concrete and between* the cable and the conduit."
Contrary to the above, the inspectors observed that conduits were
.not internally sealed where they penetrate a three hour fire barrier
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OC1286-0173-NL04
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J G Keppler, Administrator Palisades Plant Response to IEIR 86022 December 12, 1986 Discussion
NRC letter dated September 1, 1978, to Consumers Power Company transmits Amendment No. 42 to Provisional Operating License No. DPR-2 That letter states that Amendment No. 42 "adds a license condition relating to the completion of facility modifications to improve the fire protection program in response to your submittal dated March 31, 1977, as supplemented by letters dated September 29, 1977, December 15, 1977, May 15, 1978, June 19, 1978, June 29, 1978, June 30, 1978, July 28, 1978, and July 31, 1978." That same NRC letter dated September 1, 1978 also transmitted the Fire Protection SER dated September 1, 197 Of the above referenced letters upon which License Amendment No. 42 is based, only the May 15, 1978, letter refers to sealing cables to conduit; and, the only reference in that letter to sealing cables to conduit is in the design description of modification No. 3, No. 4, No. 5, and No. 1 The functional requirements for those modifications require that conduit larger than 4.inches be sealed at both ends or at the fire barrier to prevent the passage of smoke and hot gases; and, that conduit 4 inches or smaller be sealed at one end to prevent the passage of smoke and hot gase Further description of those modifications in the May 15, 1978, letter refer to cable to conduit seals oniy at the Battery Rooms and at the Southwest Penetration Roo Thus, those would be the only cable to conduit seal modifications referred to in paragraph 3.E of Provisional Operating License DPR-2 As indicated in our submittal dated October 13, 1980, Consumers Power Company had completed the modifications regarding conduit seals as required by paragraph 3.E of Provisional License DPR-2 This has been further documented in Supplement 2 (February 10, 1981) to the September 1, 1978, Fire Protection SE The foregoing was discussed by telephone with the NRC staff on December 2, 198 After thorough review of the correspondence relating to paragraph 3.E of Provisional Operating License DPR-20, and with consideration of the configuration of the smoke and hot gas seals in 4 inch and smaller conduit at the Palis.ades Plant, Consumers Power Company concludes that there was no violation of said paragraph 3.E and that the violation finding relating to paragraph 3.E should be withdraw During the July 28, through September*3o, 1986, 10CFR50 Appendix R inspection, Consumers Power Company's SFPE certified Fire Protection Engineer and the NRC Fire Protection Engineer disagreed as to the required method of sealing Junction Boxes and Pull Boxes when they are located in conduit 4 inches or smaller and are within 60 inches of a rated fire barrie NRC Fire Protection Engineers interpret the criteria (Appendix A to BTP APCSB 9.5-1 and Generic Letter 86-10) as requiring OC1286-0173-NL04
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J G Keppler, Administrator Palisades Plant Response to IEIR 86022 December 12, 1986
the cable to be sealed to the conduit at the entrance to the Junction Box or Pull Bo Consumers Power Company Fire Protection Engineers interpret the same criteria as allowing the Junction Box or Pull Box by its construction to provide the required sea.l to prevent passage of smoke and hot gase Corrective Actions Taken and Results Achieved Consumers Power Company, as stated in Item 8 and Attachment 5 in our October 14, 1986 submittal, maintains that the construction of a Junction Box or Pull box in conduit 4 inches and smaller located within 60 inches of a fire barrier provides a smoke and hot gas seal which meets the applicable criteri However, to address the difference in interpreta-tion of the applicable criteria as was found during the July 28, through September 30, 1986, Fire Protection Inspection, Consumers Power Company has identified the locations where cable to conduit seals are required to comply with the more recent NRC interpretation of the criteria and will seal the cable. to conduit at tho.se location Meanwhile, until full compliance is achieved, hourly fire patrols will be performed in the affected area Corrective Action To Be Taken To Avoid Further Violations The criteria for sealing conduit penetrations at Palisades will be modified to include the requirement to seal cables to conduit at the entrance to Junction Boxes and Pull Boxes when those Junction Boxes and Pull Boxes are in conduit 4 inches and smaller and are located within 60 inches of a fire barrie Date When Full Compliance Will Be Achieved Full compliance will be achieved on or before April 30, 198 ITEM 2 (NONCOMPLIANCE 255/86022-09)
10CFR50.48(b) in part requires that all nuclear power licensed to operate prior to January 1, 1979, shall satisfy the applicable requirements 'of Appendix R to this part, including, specifically, the requirements of Section III. J. Emergency Lightin Contrary to the above, during this inspection, the inspectors observed that emergency lighting was not available in the Volume Control Room, Boric Acid Storage Room, 590' level near the air ejector, and Inside Containment near Valve No. 2001 *
OC1286-0173-NL04
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J G Keppler, Administrator Palisades Plant Response to IEIR 86022 December 12, 1986 Corrective Actions Taken and Results Achieved Emergency Lighting Units (ELUs)
h~ve been installed at the Boric Acid Tank, at the Volume Control Tank and on the 590' level in the Turbine Building near the air ejecto Compensatory action in the form of requiring operators to carry portable lights while performing Emergency Operating Procedure EOP 10.2 will remain in effect until the problem of installing ELUs inside containment along the access and egress routes to and at CV-2001 is resolve Additionally, other methods of closing CV-2001 which do not require entry into containment are being evaluate Corrective Action To Be Taken To Avoid Further Violations All areas containing safe shutdown equipment and the access and egress routes thereto are being re-evaluated regarding the requirement to provide ELU If locations in addition to those which already have ELUs installed are determined, ELUs will be installed at those additional location Date When Full Compliance Will Be Achieved Full compliance has been achieved at the Boric Acid Tank, the Volume Control Tank and the 590' level in the Turbine Building near the air ejecto Full compliance including, if necessary, the lighting required to manually close CV-2001 will be achieved prior to the startup from the 1987 Maintenance Outag Kenneth W Berry (Signed)
Kenneth W Berry Director, Nuclear Licensing CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector - Palisades OC1286-0173-NL04
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