ML18052A748
| ML18052A748 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/20/1986 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML17216A841 | List: |
| References | |
| NUDOCS 8610270452 | |
| Download: ML18052A748 (3) | |
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consumers Power POWERING lllllCHlliAN"S PROliRESS General Offices:
1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-1636 October 20, 1986
- Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission W~shington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
TECHNICAL SPECIFICATION CHANGE REQUEST -
REMOVAL OF CONTAINMENT AIR COOLER FAN V4A
. Kenneth W Berry Director Nuclear licensing Attached are three (3) originals and thirty-seven (37) conformed copies of a request to change the Palisades Technical Specifications.
The attached proposal requests removal of the V4A containment air cooler fan from the Technical Specifications. Additionally, a new basis is provided for section 3.4 and an editorial correction is made regarding the service water cooling flow to the containment air coolers in section 5.2.3a.
Recent system testing of the service water system has shown inadequate criti-cal service water flow distribution to required components.
As a result, several tests of the system have been conducted and coupled with analysis have*
led to a decision to modify the operation of the VHX-4 containment air cooler with which the V4A fan is associated.
In the event of a loss of off-site power, the V4A cooling fan is fed from diesel generator 1-1.
Diesel generator 1-1 also has aligned to it two containment spray pumps.
These spray pumps provide adequate cooling capabili-ty to the containment without consideration of V4A which was never assumed operational in an accident analysis.
Although the VHX-4 air cooler was not considered in any accident analysis and its removal from the Technical Specifications does not involve a significant hazards consideration, Consumers Power Company does intend to maintain its environmental qualification and keep the unit in an operational condition via administrative procedures based on the Technical Specification requirements for the remaining coolers.
The unit will be used for cooling during normal operation and upon a Safety Injection Signal (SIS) its cooling water supply will be i~olated to divert service water to other required safeguards compo-nents.
If off-site power is available, and provided cooling water can be restored to VHX-4, the unit may, if desirable, be restored during a post-accident recovery.
The operability of VHX-4 depends upon both the V4A fan
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Director, Nuclear Reactor Regulation Palisades Plant TSCR - Removal of Containment Air Cooler Fan October 20, 1986 2
motor and the service water flow control valve which, in turn, depends on instrument air and the valve's ability to operate when submerged.
In the long term, Consumers Power Company intends to resolve all problems associated with the low service water flow condition.
Final resolution to the problem,may involve major modifications to the system pumping capacity.
This change to the Palisades Technical Specification is request*ed in the interim.
Our present schedule includes plant heatup on October 26, 1986 and bringing the reactor critical on November 10, 1986.
In order to_ meet this schedule, Consumers Power requests the NRC take immediate action on this Technical Spe~ifications Change Request in accordance with 10CFR50.94(a)(6).
The Palisades staff and off site support organizations have worked diligently during this present outage to correct problems that were identified by our Material Condition Task Force and other problems that resulted from several identified equipment deficiencies.
The present startup schedule has been determined for several weeks as being attainable.
However the schedule is contingent on several parallel work activities associated with low service water flow, and coupled with a previously identified problem with under-designed component cooling water heat exchangers have required considerable analysis and testing to define a new system operating basis.
The analysis has included reevaluation of the containment response to a LOCA, and will also involve evaluation of the environmental qualification of safety related electrical equipment in containment.
Guaranteeing minimum service water flow to all critical components has required a series of tests to be run on the service water system.
Because the VHX-4 air cooler had not been considered in
.an accident analysis, a partial solution to the minimum flow problem has been to close the service water to the cooler.
Diverting the service water from the VHX-4 air cooler will increase the cooling water flow and enhance the cooling capability of other safeguards equipment.
While this does not com-pletely resolve the low flow problems, its consideration in parallel with several other activities is believed a reasonable short-term partial solution.
In requesting the NRC to employ the use of 10CFR50.91(a)(6), Consumers Power believes our efforts to resolve the issues have been as prudent and as timely as conditions have permitted.
We therefore request the NRC to conclude that exigent circumstances do exist in our request for this proposed Technical Specifications Change and furthermore that the change be approved such that it does not impact plant startup.
Accordingly, we request the NRC invoke the*
requirements as provided for in 10CFR50.91(a)(6)(i) through (iii) *
. In parallel with the NRC review and approval process for this change request, Consumers Power is continuing its evaluation and analysis to conclude that the best short term action will be taken in determining a new system operating basis.
We will keep the staff informed on the progress of our evaluati~n and any changes that may arise in our resolution of the issues.
Prior to startup from this current outage, we will verify the critical service water flow values to safeguards equipment are adequate for all plant conditions.
Follow-ing plant startup, we will proceed with a long-term resolution to the system operation problems.
OC1086-0144-NL04
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Director, Nuclear Palisades Plant TSCR - Removal of October 20, 1986 Reactor Regulation Containment Air Cooler Fan A check in the amount of $150.00 is enclosed as required by 10CFR170.12.
Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachments OC1086-0144-NL04 3