ML18047A684
| ML18047A684 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/06/1982 |
| From: | Johnson B CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8212090409 | |
| Download: ML18047A684 (5) | |
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consumers Power company General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-0550 December 6; 1982 Dennis M Crutchfield, Chief Operating Reactor Branch No 5 Nuclear Reactor Regulation US Nuclear Regulatory Commisssion Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - ADDITIONAL INFORMATION IN RESPONSE TO NRC REVIEWERS QUESTIONS ON JULY 1, 1982 FIRE PROTECTION SUBMITTAL Consumers Power Company letter dated October 25, 1982 provided responses to NRC questions generated during the review of the July 1, 1982 submittal on Fire Protection.
Three of the responses in October 25, 1982 indicated that further information would be supplied by the anticipated compietion date of December 1, 1982.
The three questions and Consumers Power Company responses are provided below.
QUESTION 410.2F In Section ld of Attachment A (Pages 27, 28 and 29), you state that procedures will be developed to instruct the operators to take appropriate action or as a last resort to remove DC power.
Discuss what some typical "appropriate actions" will be required.
You also note that removal of DC power will prevent spurious action in some cases (see Pages 27, 28, 29, 32 of Attachment; Page 9 of Attachment B).
Discuss how DC power will be removed to prevent such spurious action in typical cases.
Provide a schedule for developing procedures in all such cases where you specify that procedures need to be developed for necessary corrective action required to cope with malfunctioning components in the event of a fire.
RESPONSE
Following are appropriate actions for failure listed in Section ld of Attachment A, Pages 27, 28 and 29 of the July 1, 1982 Consumers Power Company Submittal.
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- - DMCrutchfield, Chief Palisades Plant Additional Info on Fire Protection Submittal December 6, 1982 RESPONSE (Continued)
- e.
2 I.
Action for "Hot Short" causing CV-0767, CV-0768, CV-0770 or CV-0771 to open:
If S/G blowdown must be stopped:
- 1.
Close manual isolation valves MS-107 and MS-108.
- 2.
Fail CV-0767, CV-0768, CV-0770, and CV-0771 closed by closing air supply valve to SV-0767, SV-0768, SV-0770, and SV-0771 and bleeding off air in air line, or manually close CV-0767, CV-0768, CV-0770 and CV-0771 using manual operator.
II.
Action for"Hot Short" causing CV-2002 (Letdown Orifice Bypass Stop Valve), CV-2202 (Letdown Line Bypass Valve), CV-2003, CV-2004, CV-2005, (Letdown Orifice Valves) or CV-2012, CV-2122 (Letdown Flow Control Valves) to fail open:
- 1.
Close CV-2001 or CV-2009.
III.
Action for "Hot Short" causing PORV-1042B, PORV-1043B, M0-1042A and M0-1043A to fail open:
Two valves iµ series must open due to hot shorts in order to result in an impact on the plant.
In order to preclude spurious opening of PORV-1042B and M0-1042A, or PORV-1043B and M0-1043A, administrative controls will be revised to require that associated breakers be locked open during power operation.
IV.
Action for "Hot Short" causing PRV-1067, PRV-1068, PRV-1071 or PRV-1072 to open:
- 1.
Open breaker 10~ on Dll and breaker 203 on D21.
V.
Action for 0 Hot Short" causing CV-2117 (Auxiliary Spray Stop Valve) to open:
- 1.
Close CV-1057 and CV-1059 as necessary to maintain PCS pressure.
- 2.
If necessary, secure letdown and charging.
VI.
Action for "Hot Short" causing M0-3072.to open:
- 1.
Open breaker 52-217 on MCC2.
- 2.
Manually position M0-3072 to desired position.
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DMCrutchfield, Chief Palisades Plant Additional Info on Fire Protection Submittal December 6, 1982 RESPONSE (Continued)
VIL Action for failure of CV-1057 or CV-1059 (excessive spray):
- 1.
Switch Pressure Controller to other channel.
Shift Pressure Controller to manual and set to zero.
- 2.
Place handswitch for CV-1057 and CV-1059 in "Close" position.
-~
3
- 3.
If necessary verify reactor is tripped, successively trip PCP's until pressure control is regained.
If all PCP's are stopped or SIS is. received, go to Natural Circulation in accordanc.e *with ONP-21.
QUESTION 410.4F As indicated in Consumers Power Company submittal of October 25, 1982, an exemption request regarding the disconnect/connect procedure of leads at the penatration for the auxiliary shutdown panel's source range monitor was being prepared.
RESPONSE
Exemption request submitted as Attachment 1.
QUESTION Provide steam generator pressure indication at the auxiliary shutdown panel.
RESPONSE
In section IV.1 of Enclosure 4 of NRC letter dated April 7, 1982, it was stated that the NRC was requesting instrumentation to indicate steam generator pressures be provided for the intended use of providing surveillance regarding proper operation of systems used in maintaining sufficient cooling capability.
It was also indicated that the NRC staff would accept alternative instruments and methods if suitable justification was provided.
Consumers Power Company alternative to steam generators pressure instrumentation at the auxiliary shutdown panel is to first use the primary coolant system cold leg temperature indication to determine steam generator temperature since they will be equal at zero power conditions.
Next, the steam generator pressure can be determined by finding the saturation pressure corresponding to the cold leg temperature.
This alternative method was 0Cl282-0004A-NL02
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DMCrutchfield, Chief Palisades Plant Additional Info on Fire Protection Submittal December 6, 1982 RESPONSE (Continued) 4 discussed with the NRG staff resulting in the identification of a concern that should an atmospheric dump valve or relief valve open and cause an uncontrolled cooldown, the indication of such would have a time delay by using the alternative method. Consumers Power Company has determined that this delay between the drop in steam generator pressure and the drop in cold leg temperature would be small; in the range of 15 to 60 seconds. Furthermore this delay in detecting a drop in steam generator pressure by using cold leg temperature is insignificant compared to the time required to try to isolate or repair the valve, since there are not controls at the auxiliary shutdown panel to directly control steam generator pressure.
Finally, the opening of a atmosphere dump valve or relief valve would in the majority of cases be audible to the operator thus giving him immediate indication of the supposed event.
Consumers Power Company is of the opinion that this reasoning fully justifies our alternative method to be used in place of steam generator pressure instrumentation.
Brian D Johnson Staff Licensing Engineer CC Administrator, Region III, USNRC NRG Resident Inspector - Palisades OC1282-0004A-NL02
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ATTACHMENT 1 EXEMPTION REQUEST ITEM 1 10 CFR 50 Appendix R Section III.G.l.a contains the requirement that all equipment necessary to achieve and maintain hot shutdown be free of fire damage.
In a telephone conference call with the NRC staff October 15, 1982, it was stated that the disconnect/connect procedure of the leads for source range flux monitor at the auxiliary shutdown panel constituted a repair and therefore does not meet this requirement.
The following is our justification for an exemption request to the above requirement for the source range flux monitor at the auxiliary shutdown panel.
Consumers Power Company has determined that the amount of time available at hot shutdown before boron injection would be needed to compensate for xenon decay would be in excess of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> because peak xenon buildup occurs at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after shutdown.
Since the connection for the auxiliary source range flux monitor is at the auxiliary shutdown panel the operator would make the connection immediately upon arrival at the auxiliary shutdown panel.
Consumers Power Company further contends that this cable connection is merely an operator action required to attain safe shutdown and should not be classified as a "repair", since cable with plug-in connectors will be provided.
For the reasons stated above, Consumers Power Company hereby requests an exemption from the requirements of Section III.G.l.a of Appendix Ras it applies to the source range flux monitor allowing it to be inoperative until the auxiliary shutdown panel is manned by the operator and the appropriate disconnect/connect action is made as part of the panel activiation procedure.
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