ML18051B451
| ML18051B451 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/19/1985 |
| From: | Bordine T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8506270145 | |
| Download: ML18051B451 (5) | |
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consumers Power company General Offices: 1945 West Parnell Road, Jackson, Ml 49201 *.1517J. 7SS-0550 June 19, 1985
- Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC DOCKET 255 - LICENSE DPR PALISADES PLANT - FIRE PROTECTION EXEMPTION REQUEST ~ COMPLIANCE Tq 10CFR50.48 & APPENDIX R - REVISION 7 I
NRC and Consumers Power Company staff representatives participated in a conference and plant tour on June 3 and June 4, 1985 at the Palisades Plant to resolve a number of requested exemptions to 10CFR50, Appendix R, "Fire Protection." That conference and an additional conference call held on June 6, 1985, resulted in the need to modify previously *submitted exemption requests.
These changes are summarized below and detailed in the.attachments to this letter.
These attachments are revisions to those which have been previously submitted.
Additionally, Attachment lA has been revised to include additional essential equipment.
Furthermore, Consumers Power Company has decided to install isolation switches in lieu of using off site assistance as originally requested in Attachment 13 as this request was denied by the NRC by letter dated February 13, 1985.
Please note that for the purposes of completeness, this letter resubmits all previously submitted attachments with the exception of Attachments 7 and 14.
R~vised Attachments 7 and 14 will be provided at a later date for the reasons explained below.
All revisions are identified by bars in *the margin.
I.
Summary of requested changes resulting from the June 3 & 4, 1985 plant visit by NRC staff and from the June 6, 1985 telephone conversation between NRC and Consumers Power Company staff representatives.
A.
Attachment No. 3 - Intake Structure Upon further review, Consumers Power Company has determined that there is adequate protection for the service water pumps and their alternate system, the diesel driven fire pump.
While both of these pumps are located in the same fire area (ie, the Intake Structure), the installation of a radiant energy shield around the diesel driven fire pump resulted in the formation of separate zones within this area.
In addition, credit has been taken for the 96 inch circulating water inlet pipe which passes between the diesel fuel transfer pumps and the service water pumps.
OC0685-0004A-NL03 A oo\\i!
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Director, Nuclear Reactor Regulation Palisades Plant Fire Protection (Rev 7)
June 19, 1985 2
Therefore, we have concluded that the requirements of 10CFRSO, Appendix R,Section III.G.3,.as applied.to the Intake Structure, are satisfied.
Accordingly, the current exemption request in Attachment 3 (Rev. 1 dated July 9, 1984) is withdrawn.
At the request of the NRC, Consumers Power Company has determined that a fire in the Intake Structure which renders all three service water pumps inoperable will not result in degraded plant voltage conditions or a loss of offsite power.
Furthermore, the existing Intake Structure sprinkler locations will be reviewed and, if necessary, modified to ensure that the sprinkler heads will be maintained free of interference in accordance with National Fire Protection Association. (NFPA) No. 13.
Procedures which ensure the expeditious replacement of a fire damaged service wateF pump motor in accordance with the applicable requirements of 10CFR50, Appendix R, Section III.G.l.b, will be prepared and issued.
Consumers Power Company requests that the NRC evaluate our conclu~ion that the Intake Structure satisfies the requirements of 10CFR50, Appendix R, Section III.G. 3 based on the information given above and' in the current revision of Attachment 3.
B.
Attachment No. 4 - Separation of the *East & West Engineered Safeguards Areas In the event of a fire in one of the Engineered Safeguards areas, the equipment in the other area is necessary for cold shutdown and has been determined to comply with 10CFR50, Appendix R, Section *III.G. l. The current request for exemption from III.G.2, Attachment 4 (Rev. 1 dated July 16 1984), is* hereby withdrawn.
The NRC is requested, as agreed during the June 6, 1985 telephone conference, to evaluate these areas as separate* fire areas.
Th.is evaluation should be based on the information provided in the current exemption request and section 5.9.1 of the September 1, 1978 SER which states that the safeguards area is made up of two zones separated by a barrier having three hour fire resistance.
- C.
Attachment No.* 5 - Rated Barriers Various fire doors are described in paragraphs labeled "a" through "n".in the current exemption request (Rev. 1 dated July 16, 1984). Only the paragraphs labeled "f" (describing the door'No. 168 between the lC SWCR Room and the 590' corridor) and "i" (describing the doors between the cable spreading room* and the north battery room and the door. between the north and south battery rooms) separate areas containing alternate circuits.
The doors and frames described in paragraph "f" will be modified to meet NFPA No. 80.
The doors and frames, described in paragraph "i" as well as those described in paragraphs "k," and "l" will either be inspected by a nationally recognized testing laboratory and verified acceptable, or they will be replaced_.
OC0685-0004A-NL03
Director, Nuclear Reactor Regulation Palisades Plant Fire Protection (Rev 7)
June 19, 1985 3
Consumers Power Company requests that the NRC evaluate our determination that the bulletproof or watertight doors described in paragraphs a, b, c, d, g, h, j, m, and n of the current exemption request are equivalent to 3-hour rated doors.
Note that these doors were evaluated in the September 1, 1978 SER, section 4.9.2, and found to be adequate.
The doors described in paragraph e, and the door giving entrance to the East Safeguards Room do not separate alternate systems and do not require additional consideration.
Therefore, the exemption request in Attachment No. 5 is withdrawn.
D.
Attachment No. 6 - Component Cooling Water Room Component Cooling Water pumps are intended to be used to bring the Plant to cold shu.tdown.
The room, including the unsealed penetration to the
- turbine building, is, as agreed to during the June 3 and 4, 1985 meeting, in compliance with 10CFR50, Appendix R, Section III.G.l.b. Therefore, the current exemption request in Attachment 6 (Rev. 1 dated July 16, 1984) is withdrawn.
In addition, a spare CCW motor with required power cable is stored onsite and identified for use during an emergency.
Procedures to install this spare motor will be prepared and issued.
The component cooling water pumps provide cooling water for the primary coolant pump (PCP) seals.
Consumers Power Company has concluded, based on loss of PCP seal cooling tests performed on similar pumps, that seal integrity would be maintained for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in the event of a fire rendering all CCW pumps inoperable.
Note that the tests referred to above were performed on stationary PCPs, and that the Palisades Plant PCPs would be stopped should CCW not be available.
E.
Attachment No. 7 - Charging Pump Room Consumers Power Company is currently in the process of evaluating the ability to use the high pressure safety injection (HPSI) pumps as a backup for the charging pumps.
This analysis should be completed shortly, and additional information regarding the current exemption request in (Rev. 1 dated July 16, 1984) will be submitted at that time.
F.
Attachment No. 14 - Instrument Separation Inside Containment Consumers Power Company is in the process of re-evaluating the need for the exemption request in the current Attachment 14 (Rev. 1 dated December 28, 1984).
This re-evaluation is prompted by recent plans to re-locate certain instruments within containment to satisfy equipment qualification criteria.
The final location of these instruments may result in adequate separation between redundant channels.
Once the final location of these instruments is determined, additional infonmrt:...fon regarding Attachment 14 will be submitted.
OC0685-0004A-NL03
Director, Nuclear Reactor Regulation Palisades Plant Fire Protection (Rev 7)
June 19, 1985 II. Additional clarifying information discussed during the June 3 and 4, 1985 conference at the Palisades Plant A.
Attachment lA
- 1.
The current attachment (Rev. 0 dated August 10, 1984) is clarified to include equipment essential for hot shutdown "when the Alternate Shutdown Panel (ASP) is used."
- 2.
The minimum time given in the current Attachment for which the PCS will remain 25°F subcooled is changed from 2.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 2.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (reference Consumers Power Company letter dated June 4, 1985).
- 3.
Neutron Flux Monitor (Source Range), Service Water Temperature at the entrance and exit of the 1-1 Diesel Generator cooling systemtCharging Pump flow, Concentrated Boric Acid Tank level and SIRW tank level are added to the current attachment as essential indicators.
4
- 4.
Enclosµre 2 to the current attachment is modified to eliminate CEN-125 as a reference and instead refers to the June 4, 1985 submittal which provides information on the calculat*ion which determines that a minimum of 2.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> will elapse before a PCS subcooling will drop below 25°F.
B.
- Attachment 13 - Local Tending of Diesel Generators The current exemption request (Rev. 0 dated August 10, 1984) to allow th.e use of off site personnel for attaining hot shutdown was denied by NRC in its letter dated February 13, 1985.
Installation of isolation switches on remote control circuits of essential hot shutdown equipment, and their
.activation by onsite personnel, will comply with Section III.L.4 and therefore eliminates the need for an exemption.
Isolation switches will be added to the remote (Control Room) control circuits for the following equipment.
- 1.
Breaker 152-107 between the 1-1 emergency DG and the lC bus.
- 2.
Breaker 152-103 between the lC bus and the service water pump P-7A
- 3.
Breaker 152-110 between the lC Bus and Station Power XFMR No. 13.
(Alternate Charging Pump Power Supply)
- 4.
Diesel Generator Voltage Control Circuits.
- 5.
Diesel Generator speed control circuits.
The 480 VAC breakers do not require isolation since local control can override any malfunction in the external control circuit.
At the time of OC0685-0004A-NL03
Director, Nuclear Reactor Regulation Palisades Plant Fire Protection (Rev 7)
June 19, 1985 5
installation of the isolation switches, redundant fusing for local control will also be added.
Detailed drawings of the location of isolation switches will be submitted to the NRC staff as soon as engineering is completed.
ZJllJad..L_
Th~ C Bo~dr.
Staff Licensing Engineer CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachments OC0685-0004A-NL03