ML18059A399
| ML18059A399 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/17/1993 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 9309290174 | |
| Download: ML18059A399 (2) | |
Text
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consumers Power POW ERi Nii MICHlliAN'S PROliRESS Palisades Nuclear Plant:
27780 Blue Star Memorial Highway, Coven, Ml 49043 September 17, 1993 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -.
GB Slade General Manager REQUEST FOR DEVIATION FROM RE~ULATORY GUIDE 1.97 REQUIREMENTS - ADDITIONAL
- ITEM By letter dated April 30, 1992 Consumers Power Company forwarded justification for a deviation from the guidance provided in.Regulatory Guide 1.97 related to the electrical separation of cables for containment isolation valve ~osition indication.
In our April 30, 1992 letter, we identified eight sets of redundant.containment isolation valve.position indication circuits that share a common raceway.
The lack of cable separation for these position indication circuits was identified as a deviation from the guidance on redundancy provided in Regulatory Guide 1.97 and the Palisades design basis.
Subsequent internal review of cable routing performed in conjunction with our Configuration Control Program (CCP) has identified one additional set of containment isolation valve position indication circuits that do not meet the separation requirements of Regulatory Guide 1.97 and the Palisades design basis. Therefore, we *request that this add it i ona 1 set of containment * * * *
- isolation valve position indication circuits (identified.below) be included in our previous request to deviate from the Regulatory Guide 1.97 guidance on redundancy.
CONTROL VALVE CV2083, 2099 PENETRATION NUMBER 44 FUNCTION Primary Coolant Pump Seal Containment Isolation Valves
_7~1_':)1J)
- .930929017 4 9"3091. 1".....*.
PDR ADOCK 05000255 p
P_DR.
A CMS' ENERGY COMPANY
Justification for deviation from the Regulatory Guide 1.97 guidance on redundancy was provi~ed in our April 30, 1992 letter and is restated below:
- 1.
The primary coolant pump seal containment isolation valves are pneumatically operated and fail in the closed (i.e., safe) position on loss of either electric power or air pressure.
- 2.
Lack of position indication would not result in misleading the operator.
The operator merely has to place the isolation valve handswitch in the closed position to assure that power is removed from the solenoid operator thus closing the valve.
- 3.
The primary coolant pump seal contaiment isolation valves are in a system which is not needed for safe shutdown of the plant after an accident. Therefore, the safe position of the valves is the closed position.
The operator would have no need to open the valves.
NRC review and approval of this deviation, as well as the deviations identified in our April 30, 1992 letter, is requested.
£~p~.
Gera 1 d.B Slade Genera 1. Manager CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades 2