ML18054A706
| ML18054A706 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/27/1989 |
| From: | Frisch R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TAC-72959, NUDOCS 8905020280 | |
| Download: ML18054A706 (14) | |
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consumers Power POW ERi Nii NllCHlliAN"S PROGRESS General Offices: 1945 West Parnall Road, Jackson,* Ml 49201 * (517) 788-0550 April 27, 1989 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ON MODIFICATION TO IMPROVE OFFSITE POWER RELIABILITY (TAC No 72959)
Nuclear Regulatory Commission letter dated May 18, 1988 acknowledged Consumers Power commitment to perform modification of the Palisades offsite power system to improve reliability.
The letter requested that Consumers Power provide the Commission with a copy of the safety evaluation performed for this modification pursuant to 10CFR50.59.
Additionally, the letter suggested that Palisades Technical Specifications Section 3.7 be upgraded to present-day requirements, including all modes of plant operation.
The purpose of this letter is to provide the requested safety evaluation and to discuss Consumers Power Company plans for revising the Electrical System Technical Specification requirements.
A copy of the offsite power reliability modification conceptual design safety evaluation performed pursuant to 10CFR50.59 is provided in the Attachment.
This conceptual design safety evaluation concludes that installation of the additional source of offsite power to the Class lE 2400 volt safeguards buses and replacement of the main generator bolted disconnect links with a motor operated switch does not result in an unreviewed safety question.
Therefore, this safety evaluation is provided for information only.
Based on our conclusion that the proposed off site power modification does not result in an unreviewed safety question, Consumers Power Company has begun initial work necessary to implement this modification.
Civil work to enlarge the Palisades switchyard and to place foundations for major equipment is currently in progress.
Installation of cable from the switchyard to the plant is scheduled for completion this summer.
Installation of the main generator isophase bus motor operated disconnect switch, final electrical connections and completion of the modification is planned for the 1990 refueling outage, currently scheduled to begin during the first quarter of 1990.
Part of the offsite power modification, included installation of an additional_
station power transformer to supply the cooling towers during power operations.
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Nuclear Regulatory Commission Palisades Plant Response to Mods to Improve Offsite Power April i7, 1989 2
Installation of this transformer was completed during the 1988 refueling outage.
A sunnnary of the safety evaluation for the Facility Change (FC) which incorporated the additional station power transformer is included as item FC-799 in the "1988 Annual Report of Facility Changes, Tests and Experiments" which was submitted to the Nuclear Regulatory Commission by letter dated March 31, 1989.
Consumers Power Company has previously connnitted to submit restructured Technical Specifications in early 1990 in conjunction with the industry and NRC initiatives for improved Technical Specifications.
In the long term, the restructured Technical Specification program will standardize the electrical section Technical Specifications.
We consider these changes will satisfy your request to upgrade Section 3.7 of the Technical Specifications to present-day requirements.
Necessary revisions to the existing Technical Specifications to incorporate the additional source of off site power to the Class lE system will be submitted prior to the completion of the installation of the modification.
Senior Licensing Analyst CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment OC0489-0003-NL02
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OC0489-0003-NL02 ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 SAFETY EVALUATION OFFSITE POWER RELIABILITY MODIFICATION FACILITY CHANGE - 800 April 27, 1989 11 Pages
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DOCUMENT REVIEW TRANSMITTAL SHEET Proc No 10.41 Revision 12 Page 1 of 2 1
TITLE:* Df.fs/ft. ~c~ REu~&u1"'f Hat>1f1c1:Jfio,.J DOCUMENT NUMBER:
Fe-800 (Caucur11AL DES/<11")
ORIGINATOR:
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DATE: Jl..._/_3,J _ _/ 98 REVISION NUMBER: """"µ'---A __ _
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========================================================================
2 REVIEW TYPE New Procedure Revision
__ Temporary Procedure Periodic Review Cancellation Minor Revision
========================================================================
3 REVIEWS REQUIRED (Per Admin 10.42)
__ PRC __ QA Tech ALARA __ Safety Eval Admin Envir
========================================================================
4 REVIEW WAIVERS PRC*
__ QA*
Tech A LARA Admin Envir Responsible Department Head Approval: ------------Date: __ / __ / __
PRC N E D L N A R
COMMENTS F c M A v SAFETY c
REVIEWERS INITIAL/
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Procedure 13-10 ATTACHHEHT 1 Revision 3 Page 1 of 1 It* To Be Ev.alu&ted:
Item Identification:
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- 1.
Does the item involve a change to procedures as described in the FSAB.?
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Does the item require a change to the Technical Specification?
List affected and reviewed section(s)
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If any Safety Review question listed above 19 answered Yes, perform a written Safety Evaluation.
If all Safety Review questions listed above are answered No, a written Safety Evaluation is not required.
However, this Attachment shall accompany other documentation for the item being evaluated in order to provide documentation that a Safety Evalu&tion was not required.
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SECTIOll I
- 1. Will the probability of an accident previously evaluated in the FSAB. be increased?
- 2. Will the consequences of an accident previously evaluated in the FSAB. be increased?
- 3. Will the probability of malfunctions of equipment important to safety be increased?
- 4. Will the consequences of a malfunction of equipment important to safety be increased?
- 5. Will the possibility of an accident of a different type than any previously evalU&ted in the FSAI be created?
- 6.
Will the p~ssibility of a malfunction of a different type than any previously evaluated in the FSAB. be created?
- 7. Will the margin of safety as defined in the basis for any Technica~ Specification be redaced?
.1 Yes If any of the above questions are answered Yes, an unreviewed safety question is involved.
A written Safety Analysis shall be prepared and the item shall not be implemented without prior NRC concurrence.
If all of the above questions are answered No, a written Safety Analysis shall be prepared to provide the documented basis for concluding the proposed item does not constitute an unreviewed safety question.
SICTIOll II
- 1. Should tb.is be included in an FSAB. update?
- 2.
Is prior NIC anroval and/or an application for amendment to the Palisades Operating Li~ense required?
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Procedure 13-10 ATTACHMENT 3 Revision 3 Page 1 of 1 Rev~
Page l
DESCRIPTION OF ITEM Safety Analy1il FC-800 Page 1 of 5 This facility change will add a separate 345-2.4 kV safeguard transformer in the switchyard to provide a physically independent source of power to the plant to enhance conformance to General Design Criteria 17.
This will become the normal source of supply to the "le", "lD" and "lE" buses.
The power to the transformer will be from the switchyard "F" bus and the circuit to the plant will be run underground.
At the plant, a switchgear house with two breakers will be added to provide isolation of the 2400 V system from the new safeguard transformer and from the existing Station Power Transformer 1-2. The delayed access circuit through the Station Power Transformer 1-2 will remain function-al. Operation with Station Power Transformer 1-2 supplying buses lC, lD and lE will be allowed for backfeed operation with the reactor shutdown or as an optional onsite source.
A main generator isophase bus motor operated discon-nect-switch will be added to replace the disconnect 1 inks.
This new disconnect switch will reduce the time required to energize the-delayed access circuit.
The inmediate access circuit from the switchyard "R" bus to the Startup Trans-former 1-2 will remain unchanged.
Figure 1 shows the existing of fsite power arrangement and Figure 2 shows the offsite power arrangement after this f acili-ty change has been completed.
The safeguard transformer will not be provided with an automatic water deluge system.
A deluge system for this transformer is not required due to its location).n the switchyard, which is remote from the plant.
Physical separa-tion provided between the transformer and the switchyard 11R11 bus provides assurance that the "R" bus would be available to provide offsite power to the safeguard buses in the unlikely event of a fire in the safeguards transformer.
The safeguard transformer will be supplied with an automatic load tap changer (LTC) which will correct voltage due to load changes.
New differential current and high side neutral ground relays will be added to the transformer which will initiate a trip of the "F" bus primary lockout relay.
New overcurrent and sudden pressure relays will also be added which will initiate a trip of the "F" bus backup lockout relay.
The primary and backup lockout relays will in turn trip the "F" bus breakers, the safeguard feeder breaker 152-401 and initiate a fast transfer of the 11lC 11,
1110 11 and "lE" buses to the Startup Transformer 1-2.
The safeguard transformer will have a high side motor operated disconnect (MOD) switch (24Fl) that is interlocked with all the "F" bus breakers to ensure that the switch cannot be operated if the "F" bus is energized.
The HOD switch will have local control and position indication in the Substation Relay Building and remote control and position indication will be in the Plant Control Room on Panel C07.
A new watthour metering package, located in the Substation Relay Building, will be used to monitor the safeguard transformer high side power.
This package can also be used for future billing if recording devices are added.
Ancillary equipment will be provided to send information via the existing SCADA System to HEPCC and Parnall Power Control.
The safeguard transformer 2400V low side watthours will be metered using a new meter in the Plant Control Room.
This meter can be used to provide plant production information the same as existing station power 2400V loads.
FD1288-0029A-PT12
Safety Analysis FC-800 Page 2 of 5 The switchgear house will be located next to the Station Power Transformer 1-2 and protected from the Startup Transformers by a new fire wall.
Approximately six feet of the existing cinder block wall which is between the station power transformers and the startup power transformers will be removed.
A new wall 20 feet long by 18 feet high will be built parallel to the existing wall but nine feet south and with the east end of the wall starting at the existing fence.
This will provide space and separation for the new safeguard switchgear house.
The underground cables from the switchyard will enter into the bottom of the switchgear house.
To cross the roadway adjacent to the switchgear house, the cables will be routed through a prefabricated trench which will be at grade level.
In order to install the trench, the oil pit drain pipe from the reserve transformer X09 will be relocated.
The two breakers in the switchgear house will be designated 152-401 for the feed from the safeguard transformer and 152-402 for the feed from the Station Power Transformer 1-2.
The circuit from the secondary bushings of station power transformer 1-2 to the line side of breaker 152-402 will be enclosed bus duct.
Enclosed bus duct will also be used between the load side of breakers 152-401 and 152-402 to the termination compartment on station power transformer 1-2.
The termination compartment is where the cables for the lC and 10 switch-gear are connected.
The existing feeder cables from the Station Power Trans-former 1-2 to the lC and 10 buses were analyzed for accident transient loads. -
It was determined that a minimum time required to exceed the 90°C cable design temperature was in excess of 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />, assuming a 630A preload on the cables.
The lC a~d 10 feeder cables will be upgraded to handle the transient loading.
The cables from the lE switchgear will also be upgraded and reconnected to terminate directly at the switchgear house.
The lE cables are being replaced because the useful life was reduced to 9.9 years as a result of previous overloads on the circuit.
A breaker interlock scheme for breakers 152-401 and 152-402 will be used to ensure that only one breaker can be closed at any given time.
In addition, the closing circuits of breakers 152-401 and 152-402 shall be interlocked to ensure that breakers 152-105, 152-203 and 152-302 are open.
No synchronizing relays will be provided for breakers 152-401 and 152-402. Transfer of loads from the startup transformer 1-2 to the safeguard transformer or station power trans-former 1-2 shall be on a bus by bus basis using existing synchronizing equip-ment.
No auto transfer from startup transformer 1-2 to the safeguard transformer will be provided.
The existing 187 differential relay scheme for station power transformer 1-2 will be modified to delete the use of the current transformers (CT's) on the load side of breakers 152-105, 152-203 and 152-302 on Buses "lC", "lD" and "lE" respectively, and incorporate a new CT on the load side of breaker 152-402.
The 187 relay will trip the 3868 relay which will initiate a fast transfer and turbine trip.
A new differential zone scheme for the safeguard feeder bus will be added which will utilize the existing CT's on the load side of breakers 152-105, 152-203 and 152-302 with the CT's on the line side of breakers 152-401 and 152-402.
The activation of the 187-1 differential relay will initiate a trip of both breakers 152-401 and 152-402 plus a fast transfer of the 11lC",
111011 and 11 1E" FD1288-0029A-PT12
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Safety Analysis FC-800 Page 3 of 5 buses to the startup transformer 1-2.
Breaker 152-402 will be provided with a breaker protection relay control scheme which will initiate a 0.5 second delayed trip signal to the 386P primary lockout relay should the 152-402 breaker, closed to supply 2400V loads from the delayed access circuit, fail to open upon activation of the new 187-1 differential relay.
The existing scheme that initiates a fast transfer of the lC, 10 and lE bus loads from station power transformer 1-2 to start up transformer 1-2 as a result of activation of the 386 primary, backup and coast down lockout relays, will be modified to ensure that the transfer occurs only if the Station Power Transformer 1-2 breaker 152-402 is closed. This will mean that when 2400V power to the lC, 10 and lE buses is supplied from the Safeguard Transformer 1-1 through breaker 152-401, that supply will remain unaffected by loss of the main unit.
Eliminating this fast transfer on a unit trip~ except when connected to Station Power Transformer 1-2, will decrease the probability of loss of offsite power.
The existing undervoltage protection scheme sensing voltage on Startup Trans-former 1-2 will be modified to remove the automatic startup of the diesel generators.
Starting the diesel generators on startup transformer 1-2 under-vol tage is no longer required as this undervoltage condition will not be indicative of a loss of offsite power.
Diesel ge~erator starts on turbine trip will be eliminated to min1m1ze the number of diesel starts. Starting the diesel on a turbine trip will no longer be required as a backup for turbine lube oil since a fast transfer.to startup power following a trip will no longer occur, thus decreasing the probability of*
The blocking of the SIS-X relays on Startup Transformer 1-2 undervoltage will be removed and instead the undervoltage of either bus lC or 10 will initiate the blocking.
The undervoltage of Startup Transformer 1-2 will no longer be the indication of loss of offsite power.
The undervoltage of the bus will indicate the loss of off site power and start the diesel generator supplying the bus voltage. The blocking of the SIS-X relays will still be required to prevent overloading the diesels.
The initi~tion of a load shed upon a reactor trip, turbine trip or SIS.test coincident with Startup Transformer 1-2 undervoltage will be eliminated.
The load shed will no longer be required because the fast transfer to startup power following a trip will no longer occur, thus decreasing the probability of loss of offsite power.
Redundant relays associated with the load shed will also be removed.
The 127X-ll, 12, 21 and 22 relays trip the same equipment as the 194-108 and 211 relays.
The 127X-ll and 21 relays will be reused to provide an automatic reset of the standby pump circuit for the service water pumps P7A, P7B and P7C, the low pressure safety injection pumps P67A and P67B, and the component cooling pumps P52A, P52B and P52C if a bus undervoltage occurs.
FD1288-0029A-PT12
Safety Analysis FC-800 Page 4 of 5 Fast transfer from Safeguards Transformer 1-1 to Startup Transformer 1-2 will provide for a timed out short duration close signal to breakers 152-106, 152-202 and 152-303.
This is to allow manual closure of these breakers without the need to reset lockout relays in the event the fast transfer fails.
Also the fast transfer will continue to provide a short duration trip signal to the diesel generator breaker ln the event that the fast transfer fails and the diesel generator must be ln a standby condition ready to sequence loads.
The ITC switch, which lS used to indicate whether the main transformer is on normal or backfeed, will be eliminated.
Used in its place will be a position switch from the generator motor operated disconnect switch which will indicate that the disconnect switch is open and the generator is offline.
JUSTIFICATION Items 1 and 5 - No The addition of the new offsite source to the 2400V buses will not increase the probability of an accident already analyzed in the FSAR; nor can it make possible the occurrence of an accident not reviewed in the FSAR, since the emergency (onsite) power source to the 2400V buses has not changed and it is not affected by this modification.
The accident analysis in the FSAR for loss of coolant flow, steam line rupture, steam generator tube rupture, and contain-ment pres,sure all assume the total loss of offsite power.
The 2400V buses are isolated and protected from offsite power by Class lE breakers 152-105 and 152-203.
The addition of a new 20-foot fire wall between the startup transformers and the station power transformers will not increase the probability of an accident already analyzed in the FSAR; nor can it make possible the occurrence of an accident not reviewed in the FSAR, since the fire protection that the wall provides has not changed.
Item 2 -
No The consequences of an accident already analyzed in the FSAR_will not increase because the accident analysis assumes the total loss of off site power.
This modification will not prevent the action of the safety equipment needed during the loss of coolant flow, steam line rupture, steam generator tube rupture and containment pressure accidents, thus the consequences in the analysis will remain the same.
The consequences of an accident already analyzed in the FSAR will not increase because none of the accidents assume the fire wall remains functional.
Items 3, 4 and 6 -
No The probability of an equipment malfunction analyzed, or the possibility of a malfunction not analyzed by the FSAR is not increased by this modification; nor will the consequences of an equipment malfunction be increased since the addition of a new offsite source will increase the reliability of the 2400V system.
The new offsite source will be a physically independent source because FD1288-0029A-PT12
Safety Analysis FC-800 Page S of S of locating the transformer in the switchyard, burying the supply cables to the plant underground and by powering the transformer from the switchyard F bus.
The elimination of diesel generator starts on undervoltage of the Startup Transformer 1-2 and on turbine trips will decrease the demand starts on the diesel generator, thus decreasing equipment malfunction.
The elimination of fast transfers to the startup source and load sheds upon reactor trips or turbine trips when the new offsite source is used will decrease the probability of loss of power or equipment malfunction.
The probability of a malfunction analyzed, or the possibility of a malfunction not analyzed by the FSAR is not increased by this modification; nor will the consequences of a malfunction be increased since the fire wall is a passive component and no safety-related equipment is located nearby.
Item 7 - No The margin of safety as defined in the basis section of the Technical Specifi-cation Section 3.7 will not be reduced since there will be a second physically independent source of offsite power to the 2400V system.
Having two sources of offsite power plus emergency power and the delayed access backfeed power provides an arrangement so that no single contingency can deactivate enough safeguards equipment to jeopardize the plant safety.
The fire/wall between the startup transformers and the station power trans-formers *is not discussed in the Technical Specification so the margin of safety is not reduced.
FD1288-0029A-PT12 f
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