ML18054A488

From kanterella
Jump to navigation Jump to search
Requests Exemption from Direct Reading Requirement of 10CFR50,App R,Section III.L.2.d & Fixed Fire Suppression Requirement of 10CFR50,App R,Section III.G.3 as Pertaining to Safe Shutdown After Worst Case Fire in Stated Room
ML18054A488
Person / Time
Site: Palisades Entergy icon.png
Issue date: 01/11/1989
From: Smedley R
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8901190375
Download: ML18054A488 (8)
v • d • e


Text

  • --*

~-

--~-- ---~- --------------- *--- -- ----

consumers Power POWERINli NllCHlliAN'S PROliRESS Generel Offices: 1945 West Parnell Road, Jackson,' Ml 49201 * (517) 788-0550 January 11, 1989 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

CONTAINMENT AIR ROOM -

10CFR50 APPENDIX R - EXEMPTION REQUESTS Consumers Power Company (CPC) letter dated October 4, 1985 requested an exemption from the separation criteria of 10CFR50 Appendix R, Section III.G.2 for postfire safe shutdown instrumentation located in the Containment Air Room.

During subsequent discussion with the NRG staff, it was determined that if a method to attain safe shutdown was possible without use of instrumentation located in the Containment Air Room, an exemption in regard to safe shutdown after a fire in the Containment Air Room may be allowed.

Revision 1 of the Palisades Emergency Operating Procedures (EOPs) was issued during August 1988 and contpins procedures intended for application when all containment instrumentation is inoperable.

Thus, use of the Palisades EOPs to attain safe shutdown after a worst case Containment Air Room fire is appropriate.

However, since this use of the EOPs may be considered an alternate shutdown method and the PCS status indications obtained by using these procedures are not direct reading, an exemption to 10CFR50 Appendix R -Section III.L.2 is required.

Further, since there is no fixed fire suppression in.the Containment Air Room, an exemption to 10CFR50 Appendix R, Section III.G.3 is also required.

This approach to compliance has been discussed with the NRC Palisades Project Manager and has been reviewed by the NRC technical staff as a manner in which to bring the Containment Air Room into compliance with Appendix R.

Contingent on the approval of the two exemptions discussed above, this letter withdraws our October 4, 1985 exemption request regarding separation criteria in the Containment Air Room.

For safe shutdown after a worst case fire in the Containment Air Room; the operator could, since he might have erratic or no direct indication of pressur-izer level, pressurizer pressure, and steam generator pressure, enter EOP 1.0 and be guided through the Event Diagnostic Flow Chart and ONP 25.1 to Appendix G-1 of EOP 9.0 where possible contingency action~ are listed. to this letter.contains the applicable pages of EOP 1.0, ONP 25.1 and Attachment G-1 of EOP 9.0.

OC1288-0250-NL04 I

8901190375 890111.

PDR ADOCK 05000255 p

PDC A CMS' ENERGY COMPANY

e

-N~clear Regulatory Commission Palisades Plant Exemption Requests January 11, 1989 Therefore, pursuant to 10CFR50.12(a)(2)(ii), Consumers Power Company requests exemption from the direct reading requirement of 10CFR50 Appendix R, Section III.L.2.d and.the fixed fire suppression requirement of 10CFR50 Appendix R, Section III.G.3 as they pertain to safe shutdown after a worst case fire in the Containment Air Room.

Richard W Smedley Staff Licensing Engineer CC Administrator, Region III, NRC NRC Resident Inspector - Palisades Attachment OC1288-0250-NL04 2

OC1288-Q250-NL04 ATTACHMENT 1 Consumers Power Company Palisades Plant Docket 50-255 APPLICABLE PROCEDURE PAGES FOR PCS STATUS INDICATION DURING CONTAINMENT AIR ROOM POSTFIRE SAFE SHUTDOWN January 11, 1989 5 Pages

EVENT DIAGNOSTIC FLOW CHART POWER OPERA TIO NS EVENT YES NO PERFORM "STANDARD POST TRIP ACTIONS" EOP 1.0 YES GOTO "REACTOR TRIP RECOVERY" EOP 2.0 AREALL INSTRUCTIONS COLUMN CRITERIA SATISFIED Afil2.

YOl ENERGIZED?

YES.

NO GO TO "REACTOR TRIP RECOVERY" EOP2.0 Afil2.

  • REFER TO ONP 25.1 NO Proo No EOP 1.0 Revttlon 1 Page 1of8 YOU ARE HERE NO GOTO "FUNCTIONAL RECOVERY PROCEDURE~ EOP 9.0 Afil2.

REFER TO ONP 25.2

-~

PALISADES NUCLEAR PLANT OFF NORMAL PROCEDURE Proc No ONP 25.l Revision l TITLE:

FIRE WHICH THREATENS SAFETY RELATED EQUIPMENT CAUTIOll Attachments l

through 32 are NOT a 100 percent listing of equipment which may be affected by a

fire in an area.

They only reflect equipment required for safe shutdown *.

Page 2 of 2 4.4 Refer to appropriate Attachment(s) for the area(s) affected by the fire (Refer to Index).

  • Attachments should be used to:*

NOTE:

NOTE:

4.5 4.6

a.

Identify equipment which may be affected.

b.

Identify potential consequence of failure.

c.

Identify possible alternative actions in response to Equipment failures.

Fire damage may make some steps in procedures impossible.

Attempts to meet the intent of those steps should be made with continuing use of applicable procedures.

Fire damage to cables and control circuits may cause pumps to* start or stop and valves to fail open or closed, regardless of normal. failed position when de-energized.

a.

If other procedures are in-use.{eg, EOP 9.0), then some steps in those procedures inay not be possible due to fire related damage.

Attem?t to meet the intent of affected procedure steps as compi 1tely as possible.

b.

If a fire is detected or suspected in the Containment Building which causes a loss of Control Room instrumentation, then ref er to attachment G-1 of EOP 9.0.

If a fire is detected or suspected in the following area{s), then secure the affected Train{s) of Control Room HVAC:

a.

Control HVAC Duct Work.

b.

!~ectrical Equipment Room

c.

Cable Spreading Room

d.

Control Room HVAC Equi_pment Room (one for each Train)

e.

Control Room 4.7 Maintain Plant in hot shutdown unless directed by the Shift Supervisor to commence a Plant cooldown.

Equipment repairs may be necessary prior to cooling down.

pall86-0015a-89-93

ALTERNATE INSTRUMENTATION/CONTINGENCY ACTIONS Proc No EOP 9.0 Attachment G-1 Revision 1 Page 1 of 3 FOa DIOPEllABi.E INSTRUMENTATION LOCATED INSIDE CONTAINMENT SAFETY FUNCTION

1. Reactivity Control
2. Maintenance of Vital Awi:iliaries-Electric
3.

PCS.Inventory Control INSIDE CONTAINMENT INSTRUMENT(S)

a. All Rod Position Indications
b. All Reactor Power Instrumentation
a. All PZR Level Instruments
b. All Subcooling Indications
c. All HPSI Loop Flow Instruments
d. All LPSI Loop Flow Instruments
e. All PZR Pressure Instruments OUTSIDE CONTAINMENT ALTERNATE INSTRUMENT(S)

None None None Nontt None

None*

  • = Not Affected (ie, Instrumentation Located Outside Containment) pa0386-0331GG89 POSSIBLE CONTINGENCY ACTIONS Borate PCS per EOP 9.0 success path RC-2 OR RC-3 Borate PCS per EOP 9.0 success path RC-2 Q! RC-3 Maximize SI AND Charging f ~o;-p'er success path IC-2

.~

Assume. PCS is at saturated conditions Use HPSI Discharge Pressure (**PI-0318/

  • '*PI-0375) AND HPSI Delive~Curve to estimate HPSI flow Use **FT-0306 (Shutdown Cooling Flow) for indication of total LPSI flow Use HPSI Discharge Pressure Indicators

(**PI-0318/**PI-0375)

AND Local Charging Pump Discharge Pressure

(*°*PI-0212) ~o estimate PZR Pressure

J CJ**..,

ALTERNATE INSTRUMENTATION/CONTINGENCY ACTIONS Proc No EOP 9.0 Attachment G-1 Revision l Page 2 of 3 FOa. IllOPERABLE INSTRUMEHTATION LOCATED INSIDE CONTAINMENT SAFETY FUNCTION

4.

PCS Pressure Control

,INSIDE CONTAINMENT INSTRUMENT( S)

a. All PZR Pressure Instruments
b. All PCS Temperature Indications
c. All HPSI Loop Flow Instruments
d. All LPSI Loop Flow Instruments OUTSIDE CONTAINMENT ALTERNATE POSSIBLE INSTRUMENT(S)

CONTINGENCY ACTIONS None.

. None None

Refer to Item le Estimate PCS temperature by det.ermining S/G pressure AND converting to

~responding saturation temperature as follows:

i).!! MSIVs OR MSIV Bypass Valves open, THEN use

  • '*PI-0580.to esti...-te stc*

p~essure ii) ~riitiate Temporary Modification (Refer to Admin Procedure 9.ll) to install pressure gauge to **P-8B Steam Supply Line Bleed Vatve

(**KV-MS500 for

'A' S/G OR

    • MV-MS500A for

'B' S/G)

Refer to Item le Refer to Item ld

  • = Not Affected (ie, Instrumentation Located Outside Containment) pa0386-0l31GG89

" ~,*...

ALTE1lNATE INSTRUMENTATION/CONTINGENCY ACTIONS Proc No EOP 9.0 Attachment G-1 Revision l Page 3 of 3 FOR IHOPERABLE INSTRUMENTATION LOCATED INSIDE CONTAINMENT SAFETY FUHCTION

5.

PCS/Core Heat Removal

6.
7.

Containment Isolation Containment Atmosphere

8. Maintenance of Vital Auxiliaires Water.
9.

Maintenance of INSIDE CONTAINMENT INSTRUMENT(S)

a. All S/G Level Instruments
b. All PCS Temperature Indications
c. All Subcooling Indication
d. All PZR Level Instruments
e. All HPSI Loop Flow instruments
f. All LPSt Lo.op Flo~

Instruments

a. All Containment RadiatiOn Instruments
a. All Containment Temperature Instruments
b. All Valve Position Indications for Containment Air Cooler SW Valves Vital Auxiliaries Air OUTSIDE CONTAINMENT ALTERNATE INSTRUMENT(S)

None None None None None

None None

.Breaker Indications for Containment Air Cooler Fans

  • =Not Affected (ie, Instrumentation Located Outside Containment) pa0386-0331CG89 POSSIBLE CONTINGENCY ACTIONS Maintain AFW Flow per EOP 9.0 success path, HR-3 Refer to Item 4b Ref er to Item 3b Refer to Item 3a Refer to Item le Refer*to Item ld Monitor. Containment Pressure. 1!

Containment pressure is less than l psig, THEN potential for

.having high radiation levels in Containment is NOT likely.

Ref er to Item 6a Use of Containment Spray Pumps as directed by EO~ 9.0 success path CA-3 I

I I

Retrieved from "https://kanterella.com/w/index.php?title=ML18054A488&oldid=5021632"