ML18046A841
| ML18046A841 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/03/1981 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| TASK-09-05, TASK-9-5, TASK-RR LSO5-81-08-009, LSO5-81-8-9, NUDOCS 8108050088 | |
| Download: ML18046A841 (12) | |
Text
.... **.. -
Docket No. 50-255 LS05*81-08-009 Mr. Da.v1d P. Hoffman Nuclear Licensing Administrator Consumers Power Company
- 1945.W. Parnall Rpad -
Jackson, Michigan 49201 *
Dear Mr. Hoffman:
- i.
'-n August 3, 1981
SUBJECT:
FORWARDING DRAFT EVALUATION REPORT OF SEP TOPIC IX-5 VENTILATION SYSTEMS FOR THE PALISADES NUCLEAR. POWER PLANT.
Enclosed is a *copy,of our draft evaluation of Systematic Evaluation Program Topic lX-5, *Ventilation Systems.
TIJis assessment compares your facility, as described in Docket No. 50-255, with the criteria currently used by the regulatory staff for licensing new facilities:. Please inform us 'f your as-built facility differs from the licensing basis assum.ed in our assessment within 30 day~ of receipt of tMs letter~ *we.. ~alSO'Und.ersta_nd that you are current.ly e.va.luat1ng modifications
- to-:some of the ve.nt1lation*sys~ems a~dr~$se:S in this evalu~tion, as a.result of control room h_abitab111ty and environmE!'ntal qual1,fication concerns *
. Where possi.ble indfcate if any of thes~*mo'difications will correct concerns.
indicated 1n. this evaluation, also provide imple~ntation dates *
. t This evaluation will be a basic input to the -int~grated safety assessment for your facility unless you identify changes *needed to reflect the as-built conditions at your facility. With respect to the potential modifications outljned ".in -the conclusion of this report, a determination of the need to actually imp 1 ement these changes wi U be made during the same. integrated 5~
'I
~ssessment~ This topic assessment inay be revlsed. in ~h~ future if your
.s facility design is changed or if NRC criteria relating to this toRic are.-,. //
modified before the integrated assessl_llent is completed.
~
/1 l)St.< u~~ Lo'f) 1 a1oao50000 010003 PDR ADOCK 05000255
' P PDR
>.JRC*FORM 3181101801.NRCM 024>
Sincerely,,:
Dennis M. Cr.utchfi el.d, *Chief Operating Reactors Br~nch* No. 5 Division of Licensing OFFICIAL RECORD COPY
' ').ffi(Lr ~
AD:SA:~[
Glainas 71;, /81'
- USGPO: 1980-329-824
Mr. David P. Hoffman cc M. I. Miller, Esquire Isham, Lincoln & Beale Suite 4200 One First National Plaza Chicago, Illinois 60670 Mr. Paul A. Perry, Secretary Consumers Power Corrµany 212 West Michigan Avenue Jackson, Michigan 49201 Judd L. Bacon, Esquire Consumers Pov1er Co~any 212 West Michigan Avenue Jackson, Michigan 49201 Myron M. Cherry, Esquire Suite 4501 One IBM Plaza Chicago, Illinois 60611 Ms. Mary P. Sinclair Great Lakes Energy Alliance 5711 Summerset Drive Midland, Michigan 48640 Kalamazoo Public Library 315 South Rose Street Kalamazoo, Michigan 49006 Township Supervisor Covert Township Route 1,. Box 10 Van Buren County, Michigan Office of the Governor (2)
Room 1 - Capitol Building lansing, Michigan 48913 William J. Scanlon, Esquire 2034 Pauline Boulevard Ann Arbor, Michigan 48103 Palisades Plant ATTN:
Mr. Robert Montross Plant Manager Covert, Michigan 49043 49043 PALISADES Docket No. 50-255 U. S. Environrnzntal Protection Agency Federal Activities Branch Region V Office ATTN:
EIS COORDINATOR 230 South Dearborn Street Chicago, Illinois 60604 Charles Bechhoefer, Esq., Chairman Atomic Safety and Licensing Board Panel
- u. S. Nuclear Regulatory Corrmission Washington, D. c.
20555 Dr. George c. Anderson Department of Oceanography
.rUni vers ity of Washington.
! Seattle, Washington 98195 Dr. M. Stanley Livingston l 005 Cal le Largo Santa Fe, New Mexico 87501
'Resident Inspector c/o U. S. NRC P. O. Box 87 South Haven, Michigan 49090
. ' ~,
\\
SEP REVIEW OF VENTILATION SYSTEMS TOPIC IX-5 FOR THE PALISADES NUCLEAR PLANT
I.
INTRODUCTION To assure that the ventilation systems hav*e the capability to provide a safe. environment for plant personnel and for engineered safety fea-tures, it is necessary to review the design and operation of these systems.
For example, the function of the spent fuel pool area vent-ilation system is to provide ventilation in the spent fuel pool equipment areas, to permit personnel access, and to control airborne radioactivity in the area during normal operation, anticipated opera-tional transients, and following postulated fuel handling accidents.
The function of the engineered safety feature ventilation system is to provide a suitable and controlled environment for engineered safety feature components following certain anticipated transients and design basis accidents.
II.
REVIEW CRITERIA The current criteria and guidelines used to determine if the plant sys-tems meet the topic safety objective are those provided in Standard Review Plan (SRP) Sections 9.4. l, "Control Room Area Ventilation Sys-tem", 9.4.2, "Spent Fuel Pool Area Ventilation System", 9.4.3, "Auxili-ary And Radwaste Area Venti latio.n System", 9.4.4, "Turbine Area Ven ti la-t ion System" and 9.4.5, "Engineered Safety Feature Ventilation System".
In determining if plant design conforms to a safety objective, use is made, where possible, of applicable portions of previous staff reviews.*
III.
RELATED SAFETY TOPICS AND INTERFACES The scope of review for this topic was limited to avoid duplication of effort since some aspects of.the review were perfonned under related topics.
The related topics and the subject matter are identified below.
Each of the related topic reports contains. the acceptance criteria and review guidance for its subject matter.
11,.2.A I 11-1 111-6.
111-12 VI-4.
VI-7.C.l v1~a VI-3 IX-3 IX-6 XV-20 Severe Weather Phenomena Classification of Structures, Components and Systems (Seismic and Quality)
Seismic Design Considerations Environmental Qualification of Safety Related Equipment Containment Isolation System Independence of Onsite Power Control Room Habitability Systems Required for Safe Shutdown Station Service ~nd Cooling Water Sys~ems Fire Protection Radiological Consequences of Fuel Damaging Accidents (Inside and Outside Containment)
TMI III.D~3.4 Control Room Habitability IV.
REVIEW GUIDELINES
. In determining which systems to evaluate under this topic, the staff used the definition of "systems important to safety" provided in Reference 1. The defiriition states systems important to safety are those necessary to ensure (1) the integrity of the reactor coolant pressure boundary, 1 (2) the capability to shutdown the reactor and maintain it in a safe condition, or (3) the capability to prevent, or mitigate the consequences of accidents that could result in po-tential offsite exposures comparable to the guidelines of 10 CFR Part 100, "Reactor Site Criteria". This definition was used to de-termine which systems or portions of systems were 11essenUal 11 Systems or portions of systems which perfonn functions important to safety were considered to be essential.
V.
EVALUATION The systems reviewed under the topic are The Control Room Area Venti-lation System, Spent Fuel Pool Area Ventilation System, Auxiliary and Radwaste Area Ventilation System, Turbine Area Ventilation System, and Engineered Safety Feature Ventilation System.
A.
Control Room Area Ventilation System The function of the Control Room Area Ventilation System (CRAYS) is to provide a controlled envi.ronment for the comfort and safety of control room personnel and to assure the operability of control room components during normal operating, anticipated operational trans-ient and design basis accident conditirins.
As a result of TMI this system is being reviewed generically (TMI Item 111.D.3.4, Control Room Habitability) to assure compliance with Criterion 19, "Control Room" of Appendix A, "General Design Criteria for Nuclear Power Pl ants", to 10 CFR Part 50. Therefore the CRAYS was not reviewed under this topic.
B.
Spent Fuel Pool Area Ventilation System 1
The function of the Spent Fuel Pool Area Ven~ilation System (SFPAVS) is to maintain ventilati.on in the spent fuel pool equipment areas, to pennit personnel access, and to control 'airborne radioactivity in the area during normal operation, anticipated operational transi-ents, and following postulated fuel handling accidents.
Ba~ed on our review of the ~FPAVS and the licensee's fuel h~ndling accident analysis, we determined that the system is nori ~ssential as defined in Section IV.
Reactor Coolant Pressure Boundary is defined in 10 CFR Part 50 & 50.2 (v).
C.
Auxiliary And Radwaste Area Ventilation System The Auxiliary and Radwaste*Area Ventilation System (ARAVS) services most areas within the Auxiliary Building during normal operation, including the engineered safeguard equi!lTient rooms {East and West),
the charging pump room, the primary drain tank pump room and the boric acid control area. These areas house equipment (ECC sysems and the Chemical and.Volume Control System) which operates either post-accident or for the safe shutdown of the planto Therefore the service conditions within these areas and the equipment that main-tains those conditions are considered ~ssential.
The ARAVS consists of a supply damper P0-3010 and fan V-10, two exhaust fans in parallel V-14 A & B, their associated dampers P0-1839 & P0-1840, plus vi'\\rious other dampers, filters, heaters, and chiller and associated ducts.
The normal operation of the ARAVS is with all dampers open, supply fan V-10 running, one or both.exhaust fans V-14 A & V-14 B running and the exhaust dampers P0-1839 and P0-1840 controlled by filter in-take pressure to maintain balanced airflow from all areas. Airflow controllers are used to maintain negative differentia.1. pressure in equi!lTient compartments and between controlled and non-controlled spaces. This negative pressure is used to induce infiltration into compartments, thus producing a predictable direction of airflow towards areas of increasing radiation hazard.
Final exhaust from these potentially contaminated compartments is discharged to the outside atmosphere through the ventilation stack after filtering out radioactive particulate matter in a high efficiency filter.
If loss of instrument air were to occur, the supply damper P0-3010,'
tadwaste atea ~upply aamper P0-1~09, and safeguard room supply and exhaust dampers would fail closed. (safeguard room cooling is addres-sed in Section V.E).
The supply fan and one exhaust fan are manualy tripped leaving one exhaust fan tunning to maintain a slight neg-ative pressure on the buildingo In addition if normal station power is lost, the ARAVS would fail, thereby resulting in a loss of venti-lation for the Chemical and Volume Control System which is serviced by the ARAVS.
- Since the Chemical and Volume Control System,, a system required for plant safe shutdown, relies on the ARAVS for maintaining it's opera-tional service conditions, the licensee should _determine, by analy~es, -
the effect of 1 os i ng - the ARAVS.
If the 1 icensee can demonstrate that loss of the ARAVS has no adverse effect on the chemical and volume control system, then no additional effort will be required.
However, if th:is finding can not be made then ARAVS modifications should be considered. These modifications should be directed towards**
correcting the ARAVS's loss of normal station power and/or single fa i 1 ures.
- e D.
Turbine Area Ventilation System The Turbine Area Ventilation System (TAVS) services all of the com-ponents contained within the Turbine Building.
The TAVS takes suction from outside air through four unit 9 $Upply fans or two unit 21 supply fans.
The only area which is considered to be es-
. sential -to-sa."fety._is the Auxiliary *Fe.ed *Puinp Room*.--*-If.. fa, located--
in the lower level of the Turbi;ne Building. During normal opera-tio*n,.. air is supplied to the Auxiliary Fee*d Pump Room by unit 9 of-the TAVS and exhausted back to the main Turbine Building space via an exhaust duct lOcated in the ceiling of the Auxiliary Feed Pump Room.
A single duct failure or loss of""normal station power would result in the loss of ventilation of this room.
Since the Auxiliary Feed System is required for plant safe shutdown the licensee should determine, by analyses, the effect of losing ventilat1on in this room. If the licensee can demonstrate that loss of yentil ation has no adverse effect on the Auxiliary Feed System,.
then no additional effort will be required. However, if this find-ing cannot be made then system modifications should be considered
- which will correct this system's comings 1 isted above.
E. 'Engineered Safety Features Ventiiation System The engineered Safety Features Ventilation System (ESFVS) is comprised of several systems or subsystems which either service equipment required to function after an accident or is needed to safely shutdown the plant.
Areas serviced by the ESFVS are:
Engineered Safegµard Equiµnent Rooms (East & West)
View Gallery, Switch Gear and Cable Spreading Rooms Emergency Diesel Generator Rooms Intake structure Penetration and Fan Rooms
- 1. Engineered Safeguard Equiµnent Rooms (East & West)
The Engineered Safeguard Equipment Rooms (ESER) are located in the Auxiliary Building. Equiµnent located in the*se rooms are:
HPSI Pumps Containment Spray Pumps LPSI Pumps Shutdown Cooling Heat Exchangers High Pressure Control Air Equiµnent Related Piping, Valves, Controls, etc.
- integrity of Systems Outside Containment Likely to Contain Radioactive
- Material for Pressurized Water Reactors and Boiling Water "Reactors.
.e.~
These rooms are nonnally serviced by the ARAVS.
However, when required these rooms are isolated_ from the ARAVS by non-safety grade isolation dampers in order to preclude release of higher than normal activity to the Auxiliary Buildingo *The possibil-ity of *a single failure of non-safety gr_ad~ isolation dampers could allow radiation to escape into the.Auxiliary Building, and even possibly the envir.onment.
The effects of the event have been*minimized as a result of the.TM! Acti6n Plan:.Item III.D.1.1. which required the immediate leakage reduction.-
from the type systems located in those rooms.
Each room has redundant fan coolers to maintain suitable service conditions for the equipment located in these rooms.
The water source for each of the coolers is the Service Water System.
Emergency power is supplied upon loss of normal station power.
Fan coolers VHY-27C and VHX-270, which service the west room, receive ~ower from buses M.C.C. No. l (BOl) and M.C.C. No. 2 (B02) respectively.
Fan coolers VHX-27A and VHX-27B which ser-vice east room are similarly powered from divers~ sources *.
The licensee should assess the effect of an isolation damper failure to close and detennine that the consequences of this event wi 11 not:
a}
Inhibit plant personnel from performing any task in the Auxiliary Building that may be required for plant safety; and b)
That 10 CFR 100 limits are not exceeded.
- If these findings can not be made then the appropriate modifi-cations should be considered, notably upgrading dampers.
Other.
- *than fhe isolation damper concern we find the design of this sys-
. tern acceptable.
- 2.
Viewing Gallery, Switchgear and Cable Spreading Rooms The viewing gallery, switchgear and cable spreading rooms venti**
lation system services the following areas:
Offices and Viewing Gallery Cable Spreading Room Switchgear Room 2.4KV Switchgear Toil et Battery Room The cable spreading room, switchgear room.and battery room' are considered essential because they house the reactor prbtection and control system, the instrumentation for shutdown and cool-down, the emergency power (AC and DC), and control power for safe shutdown systems all of which are considered important to safety. The major components associated with this ventilation
- system are supply FAN V-33, exhaust FAN V-47 and recirculation FAN V-43, none of which are supplied by emergency power.
The licensee should either demonstrate that the equipment ser-viced will not be adversely effected by lack of ventilation or
- consider ventilation system modifications.
- 3.
Emergency Diesel Generator Room (EDGR)
There are two emergency diesel generator rooms.
Ventilation to maintain suitable operating temperatures for the diesel and its associated electric control equipment within each room is pro-vided by two separate ventilation systems. The reliable opera-tion of these ventilation systems is considered essential to plant safety.
The major components of these systems are the two diesel genera-tors 1-1 and 1-2, and two cooling fans for each generator room, V-24A, V-24B, V-24C, and V-240 respectively.
An intake plenum is installed between the two fans in each room.
On the basis of extensive experience with this system involvi~g~
normal periods of diesel operation for test purposes, this ventilation system has been demonstrated to be of adequate design.
- 4. Intake Structure Ventilation Systan The intake structure ventilation system is addressed in this evaluation because it services the area wher.e the three service water pumps are located. These pumps are considered important to safety based on our findings presented in the SEP Topic IX-3 evaluation.
The system consists of seven supply fans, five wall mounted units (V-210-H) and two roof units (V-32A*and B). These supply fans draw atmospheric air into the building. The air is then exhausted back outside through five?roo.f mounted exhaust fans (V-30A-E).
The intake structure ventilation system was originally siied to cool circulating water pumps in addition to the service water pumps.
The existing veRtilation system is now oversized for nor-mal operation since the circulating water pumps have been removed.
In the event of a power failure, several mechanisms act to prevent any rapid heat buildup~
All other heat loads within the struct-ur~.are secured ~s the plant is shutdown, service water pipes containing cool lake water act as heat sinks, and the room is not airtight allowing some limited convectiv.e cooling to take placeo If a system failure should occur doors opening to the outside are available and should provide sufficient air flow even with multiple
.fan failures. Inspection of the intake structure at eight_.hour intervals provides additional protection against excessive* heat buildup. It's the staff's judgement that *a safety grade ventila-tion system may not be requirea for this area based on heat load to volume and heat sinks.
- 5.
Penetration and Fan Room Ventilation System (P&FR)
VI.
SUMMARY
The penetration and fan room ventilation system provides cooling air to the feedwater pipe penetration room, the main steam pipe penetration room, and fan room.
This ventilation system is con-sidered essential since it services the Main Steam System and Component Cooling Water System, both considered essential for a shutdown of the.plant.
The ventilation system is comprised of a supply fan (V-78) and exhaust fan (V-79).
The supply fan is supplied by diesel gen-erator 1-1 through M.'C~C. #1 (BOl) and the exhaust fan by diesel generator 1-2 through M.C.C. #2 (B02).
With this arrangement the "penetration and fan room" ventilation system performance is vulnerable to failure of either emergency diesel generator.
The failure of one diesel to start when re-quired results in loss of either the supply or exhaust fan.
The situation could possibly Jead to service conditions exceeding the design parameters of equiIJnent housed in these areas. The licensee should perform sufficent analyses to determine the adequacy of the ventilition with the loss of either the supply.
or exhaust fan.
Corrective ~ctions should be implemented if deemed necessary from the results of the ana 1 yses.
A.
The emergency diesel generator room ventilation system* has been *.-.*-*-
- determine~_ to b~ Q.f ~deq_uate des.!.gn.. on the.. basis of ()perating ex-perience.
B.
The isolation of the engineered safeguard equipment ventilated area remains questionable due to the presence of non-safety grade i sol a-t ion dampers.
The possible contamination of the auxiliary building due to a damper failure, while remote, should be examined to assess:
- 1. that pl ant personnel will not be inhibited from perfonni ng any task, in auxiliary building that may be required for plant safety; and
- 2. that the effects of such a failure would not result in the ex-ceeding of 10 CFR 100 limits.
C.
The "penetration and fan room" ventilation system performance is vulnerable to failure of either emergency diesel generator. The f4ilure of one diesel to start when required results in loss of eithe~
the supply or. exhaust fan.
The situation could possibly lead to ser~*
vice conditions exceeding the design parameters of equipment housed*
in these areas. The licensee should perform sufficient analyses to determine the adequacy of the ventilation with the loss of either the supply or exhaust fan.
D.
The ventilation equipment for the "Auxiliary and Radwaste Areas",
"Turbine Building", "Intake Structure", and "Viewing Gallery, Switchgear and Cable Spreading Areas 11, service equipment deemed essential for safety. However, these ventilation systems are neither safety grade, receive power from anergency sources or single failure proof.
Therefore, the lic.ensee should determine which of these ventilation systems, if any, are required to en*.
able the safety equipment, located in areas serviced, to perform their respective functions. If it,is determined that ventilation is required for any of the safety systems serviced then the appro-priate upgrading to its associated ventilation system may be required.
REFERENCES
- 1.
Regulatory Guide 1.105, System Setpoints
- 2.
NUREG-0737, Clarification of TMI Action Plan Requirements
- 3.
Final Safety Analysis Report for Palisades
- 4.
SEP Review of Safe Shutdown Systems for the Palisades Plant (SEP Topics V!I-3, V-11.A, V-11.B, *and X)
- 5.
Consumers Letter, R. Vincent to D. Crutchfield, dated June 22, 1981 Responses to NRC Question on Topic IX-5
- 6.
Bechtel Letter, J. Dotson (Bechtel) to D. Markle (Consumers), dated January 26, 1981 Transmitting Preliminary Scope Document for HVAC
- Modifications
- 7.
Consumers Letter, D. Hoffman to D. Crutchfield, dated December 19, 1980 Consumers Response to NUREG-0737
- 8.
Drawing M-115 Rev. 6 - Heating and Ventilation, Auxiliary and Containment Elevation 570'-0 11
, Drawing M-218 Rev. 14 - P&ID Heating, Ventilation and Air Conditioning, Drawing M-656 Rev. 9 - Heating & Ventilating Air Flow Diagram, Drawing E-1 Sheet l Rev. M ~ Plant Single Line Diagram, Drawing E-5 Sheets 1&4 Rev. 15 - Single Line Meter and Relay Diagram 480 volt M.C.C.