ML18052A847

Advises That SEP Topics III-2,III-4.A,V-10.B & VII-3 Addressed & Actions Taken as Appropriate to Upgrade Emergency Operating Procedures for Resolution of TMI Action Plan Item I.C.1,per Util 840511 Commitment

ML18052A847
Person / Time
Site:	Palisades
Issue date:	01/30/1987
From:	Kuemin J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-NUREG-0820, RTR-NUREG-820, TASK-03-02, TASK-03-04.A, TASK-05-10.B, TASK-07-03, TASK-1.C.1, TASK-3-2, TASK-3-4.A, TASK-5-10.B, TASK-7-3, TASK-RR, TASK-TM NUDOCS 8702060306
Download: ML18052A847 (4)

Text

consumers Power POWERING MICHIGAN'S PROGRESS General Offices: 1945 West Parnell Road, Jackson, Ml 49201 * (517) 788-0550 January 30, 1987 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

SEP TOPICS III-2, III-4.A, V-10.B, and VII-3 The subject SEP Topics (III-2, "Wind and Tornado Loading," III-4.A, "Tornado Missiles," V-10.B, "Residual Heat Removal System Reliability," and VII-3, "Systems Required for Safe Shutdown") all required review and upgrading of plant operating procedures, as necessary. Consumers Power Company, in our May 11, 1984 letter, committed to completion of these topics consistent with completion of our rewriting of the Palisades Emergency Operating Procedures for resolution of TMI Action Plan Item I.C.l.

The new Emergency Operating Procedures were issued for use in December 1986.

Our review of the procedures and incorporation of steps to comply with out-standing issues resulting from the SEP review has been completed and is summarized below for each SEP topic.

SEP TOPIC III WIND AND TORNADO LOADING The Integrated Plant Safety Assessment Report, IPSAR, NUREG-0820, October 1982, states the licensee will "review and upgrade, as necessary, the procedures to achieve safe shutdown using alternate sources of water for

• primary and secondary makeup if the preferred sources are not available." The safety injection and refueling water (SIRW) tank and condensate storage tank are assumed to fail due to the tornado wind and pressure loading. The IPSAR further states that attaining a stable hot shutdown condition can be accom-plished through borating from the concentrated boric acid tanks and adding pure water from the primary makeup tank. Additionally, it is stated, water is available from the four clean waste receiver tanks (CWRTs) and 27,000 gpm could be taken from the spent fuel pool (SFP).

The new Emergency Operating Procedure (EOP), IC-1, Inventory Control Proce-dure, directs the operator to utilize the boric acid tanks and volume control tank if the SIRW tank is unavailable. Any other actions are dependent upon which tanks are available and would not be required in the short term for this condition. The volume control tank stores enough coolant to compensate for a I OC0187-0013-NL02 1

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• Nuclear Regulatory Commission 2 Palisades Plant SEP Topics III-2, III-4.A, V-10.B, and VII-3 January 30, 1987 full to zero power decrease in the primary coolant volume without requiring '

makeup. The concentrated boric acid tanks are required by Technical Specifi-cations to contain approximately 10,000 gallons of borated water. These tanks, by themselves, provide adequate makeup to achieve safe shutdown for an extended period assuming the primary system leakage is within Technical Specifications limits. Pure water from the primary makeup tank cannot be assumed to be used as a backup water source, as it is located out-of-doors as are the SIRW tank and condensate storage tank.

The ability to use either the CWRTs or SFP is dependent upon the SIRW tank being intact. Therefore, procedures are not provided that would suggest this contingency if the SIRW tank were lost. Temporary connections could be made for supplying makeup water from these sources, but no provisions are provided for such conditions.

Backup water to the condensate storage tank is from the service water system or the fire water system which can supply the auxiliary f eedwater pumps P-8C or P-8A and 8B, respectively. Loss of the condensate storage tank and align-ment of the service water and fire water systems to the suction of the 0 auxil-iary feedwater pumps is covered in the new Loss of All Feedwater Procedure, EOP 7.0.

SEP TOPIC III-4.A - TORNADO MISSILES Same as SEP Topic III-2 above.

SEP TOPIC V-10.B - RESIDUAL HEAT REMOVAL SYSTEM RELIABILITY The IPSAR states, in Section 4.16.2, entitled "Use of Safety Grade Systems for Safe Shutdown," that Palisades uses both safety grade and non-safety grade systems to attain cold shutdown. The IPSAR further stated that non-safety grade systems may not be available following a seismic or loss-of-power event and that lack of sufficient information in operating procedures may adversely affect the ability to shutdown the reactor; for instance, failure of the non-safety grade air system could result in inoperability of steam atmospheric dump valves. The FSAR then stated that manual opening of the steam safety valves would be required. The IPSAR further states the licensee has proposed to develop appropriate documented procedures for operation of safety grade systems and components to achieve cold shutdown if non-safety grade systems are unavailable. The NRC requested confirmation that the ability of the plant to maintain the auxiliary feedwater (AFW) system operational for extended periods, using only safety grade equipment, should be confirmed.

With respect to the auxiliary feedwater system, the new Emergency Operating Procedure, EOP 7.0, Loss of All Feedwater, directs the operator to align lake water from service water system (preferred) or fire water system to the suction of the AFW pumps if the condensate storage tank is unavailable. The service water system is safety grade and the fire water system is partially safety grade ie, piping to the AFW system is seismically qualified. Other non-safety grade alternative feedwater sources such as filling the steam generators with the condensate pumps are also described in EOP 7.0. As noted, OC0187-0013-NL02

Nuclear Regulatory Commission 3 Palisades Plant SEP Topics III-2, III-4.A, V-10.B, and VII-3 January 30, 1987 the preferred backup to the condensate storage tank is from the safety grade service water system and fulfills the NRC request for confirmation to maintain the AFW system operational for an extended period.

The loss of non-safety grade instrument air system is discussed in Off-Normal Procedure, ONP 7.1. The IPSAR stated that manual actions to open the steam safety relief valves would be required on loss of the atmospheric dump valves.

This is not correct as no manual action is required to operate the safety relief valves. Secondary pressure rise would initiate opening of the safety relief valves *. Makeup water would be provided, as above, by the auxiliary feedwater system with safety grade backup.

Upon installation of the alternate shutdown panel, which resulted from 10CFR50 Appendix R requirements, the Alternate Safe Shutdown Procedure was developed.

This procedure (ONP 25.2) .establishes a stable hot shutdown condition if normal control room control is lost. Cold shutdown can be attained in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following any necessary repairs. Our position is that this procedure fulfills our general commitment to have procedures that will achieve cold shutdown following seismic or loss-of-power events.

SEP TOPIC VII SYSTEMS REQUIRED FOR SAFE SHUTDOWN The IPSAR states in Section 4.24.1, Removing of Nonessential.Loads as an Alternative to GDC 17, that, with the loss of offsite power lines and both diesel generators> power to vital instrumentation to accomplish safe shutdown would depend on batteries, for four to six hours, which is the time needed until a second offsite power source is available. To ensure battery power for four to six hours, nonessential electric loads may need to be removed in a timely manner. The IPSAR further states the licensee has proposed to develop a procedure to remove nonessential loads from the battery if the immediate sources of offsite power are not available to ensure the six-hour capability.

In September 1984, an Emergency Operating Procedure, EOP-2.1 - Loss of all Immediately Available AC Power, was issued. EOP~2.l has been renumbered as ONP-2.2 This procedure contains appropriate instructions to remove the nonessential loads. The new EOP, Functional Recovery Procedure EOP-9.0, success path MVAE-6, contains operator actions to remove the nonessential battery loads on loss of AC power and directs the operator to ONP~2.2 to strip the loads. Therefore, this commitment was met with the issuance of the previous EOP-2.1 in 1984, and the commitment continues to be met with the new EOP-9.0 and MVAE 6.

OC0187-0013-NL02

.. Nuclear Regulatory Commission Palisades Plant SEP Topics III-2, III-4.A, V-10.B, and VII-3

• 4 January 30, 1987 CONCLUSION The SEP Topics III-2, III-4.A, V-10.B and VII-3 have been addressed and actions taken as appropriate to upgrade plant procedures. Consumers Power Company considers the four issues to be closed.

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V ~am:~ ~. Kuemin Staff Licensing Engineer CC Administrator, Region III, NRC NRC Resident Inspector - Palisades OC0187-0013-NL02