ML18046A671
| ML18046A671 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/19/1981 |
| From: | Johnson B CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| GL-81-12, NUDOCS 8105270277 | |
| Download: ML18046A671 (6) | |
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._ j General Offices: 212 Wen Michigan Avenue, Jackson, Michigan May 19, 1981 Director, Nuclear Reactor Regulation Att Mr Dennis M Crutchfield, Chief Operating Reactors Branch No 5 US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - FIRE PROTECTION MODIFICATIONS
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NRC Generic Letter 81-12, dated*February 20, 1981 requested information pertaining to p~oposed modifications for compliance with Fire Protection Rule (45 FR 76602, November 19, 1980).
Consumers Power Company letter dated March 19, 1981 provided plans for achiev-ing compliance with those requirements including a design description.
Generic Letter 81-12 also requested additional detailed information to facilitate the staffs evaluation of the fire protection program at the Palisades Plant be provided by May 19, 1981.
Tne detailed informative requests of Enclosures l and 2 to Generic Letter 81-12 are provided herein as Attachments l an_d. 2.
Brian D Johnson Senior Licensing Engineer CC Director, Regioh. III, USNRC
.NRC Resident Inspector-Palisades Plant Attachments (5 pages)
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8105270~77
- 8. (a)
PALISADES PLANT FIRE PROTECTION MODIFICATIONS RESPONSE TO ENCLOSURE l, PARAGRAPH 8, INFORMATION REQUIREMENTS OF GENERIC LETTER 8l-l2 DATED FEBRUARY 20, 1981 Description of the systems or portions thereof used.to provide the shutdown capability and modifications required to achieve the alternate shutdown capability if required.
Response
The description of the modifications for the assurance of safe shutdown required by 10CFR50, Paragraph 50.48 - was submitted* by Consumers Power Company letter dated March 19, 1981.
- 8. (b)
Response
. 8. ( c)
System design by drawings which show normal and alternate shutdown control and power circuits, location of components, and that wiring which is in the area and the wiring which is out of the area that required the alternated system.
The.information provided by our letter dated March 19, 1981 describe the modification design and by either description or illustration provide the requested information.
Demonstrate that changes to safety systems will not degrade safety
. systems.
(e.g., new isolation switches andcontrql switches should meet design criteria and standards in FSAR for electrical equipment in the system that the switch is to be installed; cabinets that the switches are to be mounted in should also meet the same criteria (FSAR) as other safety related cabinets and panels; to avoid inad-vertent isolation from the control room, the isolation switches should be keylocked, or alarmed in the control room if in the "local" or
isolated" position; periodic checks should be made to verify switch is in the proper position for normal operation; and a single transfer switch or other new device should not be a source for a single failure to cause loss of redundant safety systems).
Response
- 1.
Equipment and equipment housings procured for and utilized in the modifications for the assurance of the ability to take the plant to safe shutdown have been specified to be qualified to earthquakes in accordance with.IEEE344-1975 and IEEE 323-1974 when placed
- within or interfacing with safety systems.
- 2.
Switches which transfer control or instrument functions from
~he control room to the auxiliary shutdown control panel alarm in the control room when the devices in the auxiliary shutdown.
control panel are enabled.
Either constant speed charging pump (P55n or P55C) can be connected to the non-Class lE 480V power source by the tnanual operation of air circuit breakers:
Connection of the charging pumps to their normal safety grade power sources is assured by administrative control and by padlocks.
- 8. (d)
Response
- 8. (e)
Response
- 8. (f)
Response
- 8. (g)
Response
- 8. (h)
Response
- 3.
The transfer switches of the auxiliary shutdown control panel
.Provide access to the auxiliary feedwater system for hot standby only.
No other means of achieving hot standby exists if a fire damages the control room or the cable spreading room.
In this event, a single failure on a section of one of the transfer switches could render the system or systems transferred by it inoperable from the auxiliary.shutdown control panel.
2 The auxiliary feedwater system can be placed in service by operation of the steam and feedwater valves manually at the valves and *for which there is an existing emergency operating procedure.
Demonstrate tha:t wiring, including power sources for the control circuit and equipment operation for the alternate shutdown method, is indpendent of equipment wiring in the area to be avoided.
This information is provided in our letter submitted March 19, 1981.
Demonstrate that alternate shutdown power sources, including all breakers, have isolation devides on control circuits that are routed through the area to be avoided, even if the breaker is to be operated manually.
This information is provided in our letter submitted March 19, 19.81.
Demonstrate that licensee procedure(s) have been developed which describe the tasks to be performed to effect the shutdown method.
A summary of these procedures should be submitted.
Procedures will be prepared for taking the plant to hot shutdown via the auxiliary shutdown control station in the event a fire prevents use of the control room.
Demonstrate that spare fuses are available for control circuits where these fuses may be required in supplying power to control circuits used for the shutdown method and may be blown by the effects of a cable spreading room.fire.
The spare fuses should be located convenient to the existing fuses.
The shutdown procedure should inform the operator to check these fuses.
Spare fuses will be provided for equipment operable from the auxiliary shutdown control station.
Demonstrate that the manpower required to perform the shutdown functions using the procedures of (f) as well as to provide fire brigade members to fight*the fire is available as required by the fire brigade technical specifications.
By Techni.cal Specifications, two members of the minimum shift crew that are excluded from the fire brigade are required to be on site at all times.
These two members provide adequate manpower to safely shut the plant down from either the control room or the safe shutdown area.
3
- 8. (i)
Demonstrate th~t adequate acceptance tests are performed.
These should verify that:
equipment operates from the local control station when the transfer or isolation switch is placed in the "local" position and that the equipment cannot be operated from the control room; and that equipment operates from the control room but cannot be operated at the local control station when the transfer or isolation switch*is in the "remote" position.
Response
Preoperational tests (acceptance tests) are required for all modifica-tions.
The required tests will be incorporated.
- 8. ( j)
.Technical Specifications of the. surveillance requirements and limiting conditions for operation for that equipment not already covered by existing Tech Spec.
For example, if new isolation 84ld control switches are added to a service water system, the existing Tech Spec surveillance requirements on the service water system should add a statement similar to the following:
"Every third pump test should also verify that the pump starts from the alternate shutdown station after moving all service water system isolation switches to the local control position."
Response:
- Technical Specifications will be changed to require demonstration of operability of the equipment controlled from this panel.
- 8. (k)
Demonstrate that the systems available are adequate to perform the necessary shutdown functions.
The functions required should be based on previous analyses, if possible (e.g., in the FSAR), such as a loss of normal a.c. power or shutdownon a Group I isolation (BWR).
The equipment required for the alternate capability should be the same or equivalent to that relied on in the above analysis.
Response
The systems and equipment described in response to 8(a) for performing the shutdown functions when a fire is postulated in the specified areas of the plant are the same systems and equipment that are nor-mally used for hot standby, inventory control, reactivity control and cold shutdown.
- 8. (1)
Demonstrate that repair procedures for cold shutdown systems are developed and material for repairs is maintained on site.
Response
No extemporary measures will be required to prepare for the operation of the shutdown cooling system except manual position of certain neumatically operated valves.
See also response to 8(a).
Attachment.2 PALISADES PLANT FIRE PROTECTION MODIFICATIONS RESPONSE TO ENCLOSURE 2 INFORMATION REQUIREMENTS OF GENERIC LETTER 81-12 DATED FEBRUARY 20, 1981
- 1. A Provide a table that lists all equipment including instrumentation
- and support system equipment that are required by the alternative or dedicated method of achieving and maintaining hot shutdown.
Response
- 1.
Systems controlled from the auxiliary shutdown control panel:
- a.
Auxiliary feedwater system.
- 2.
Equipment controlled from the auxiliary shutdown control panel:
- a.
Auxiliary feedwater valves CV-0736A and CV-0737A.
- b.
Auxiliary feedwater pump turbine-driven steam valve CV-0522B.
- 3.
Instrumentation systems displayed on the auxiliary shutdown control panel:
- a.
Auxiliary feedwater flow Fl 0736A and Fl 0737A.
- b.
Pressure Pressure PI 0110.
- c.
Pressurizer Level LI 0102E.
- d.
Steam Generator Level LI 0751E and LI 0752E.
- 1. B For each alternative shutdown equipment listed in 1.A above, provide a table that lists the essential cables (instrumentation, control and power) that are located in the fire area.
Response
None of the electrical cables serving the equipment listed in l.A above are located in any of the specified fire areas.
- 1. C Provide a table that lists safety related and non-safety related cables associated with the equipment and cables constituting the alternative or dedicated method of shutdown that are located in the fire area.
Response
There are no safety-related or non-safety-related cables associated with the auxiliary shutdown control panel located in any of the specified fire areas.
- 1. D Show that fire-induced failures of the cables listed in B and C above will not prevent operation or cause maloperation of the alternative or dedicated shutdown method.
- Response:
No cables identified; therefore, not applicable.
See Responses
- 1. B and 1. C.
- 1. E For each cable listed in l. B above, provide detailed electrical schematic d~awings that show how each cable is isol~~ed from the fire area.
Response
No cables identified; therefore, not applicable.
See Response 1. B.
- 2. A Identify each high-low pressure interface that uses redundant electri-cally controlled devices (such as two series motqr operatied valves) to isolate or preclude rupture of any primary coolant boundary.
Response
The single high-low pressure interface in which the low pressure system must be isolated from the high pressure system when the high pressure system is at rated pressure is in the shutdown cooling line connecting the reactor coolant system to the suction. of the low pres-sure safety injection pumps.
Isolation is provided by two.valves in series -
MO 3015 and MO 3016.
2
- 2. B Identify the device's essential cabling (power and control) and describe the cable routing (by fire area) from source to termination.
Response
Except for the areas of penetration into containment, the power and control circuits of both valves are routed through the same fire areas.
- 2. C Identify each location where the identified cables are separated by less than a wall having a three-hour fire rating from cables for the redundant device..
Response
See response to 2. B.
- 2. D For the areas identified in item 2. C above (if any), provide the bases and justification as to the acceptability of the existing design or any proposed modifications.
Response
To preclude the extremely improbable possibility of fire damage to*
the control circuitry of the shutdown cooling valves resulting in opening operations of both valves, an operating procedure will be prepared requiring the valves to be checked closed and the operating power disGonnected from both before pressurizing the primary system greater than 260 psig.