ML18353A992
| ML18353A992 | |
| Person / Time | |
|---|---|
| Site: | Palisades, Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 05/27/1975 |
| From: | Sewell R Consumers Power Co |
| To: | James Keppler NRC/IE, NRC/RGN-III |
| References | |
| IEB-75-004, IEB-75-004A | |
| Download: ML18353A992 (5) | |
Text
,.-*
/.
(
consumers Power company
©~W General Offices: 212 West Michigan Avenue, Jackson, Michigan 49201
- Area Code 517 788-0550
(
\\_
Mr. J. G. Keppler US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Dear Mr. Keppler:
May 27, 1975 Re:
Dockets No 50-155 and No 50-255 Attached is Consumers Power Company's response to IE Bulletins No 75~04 and 75-04A for the Big Rock Point and Palisades Plants.
This response was requested by your letter dated April 3, 1975.
Several areas of review and follow-up action have not yet been completed.
These areas are question No 2 from IE Bulletin No 75-04 and question No 3F from IE Bulletin No 75-04A.
Further response with regard to these two questions will be submitted by June 23, 1975-Yours very truly, Ralph B. Sewell (Signed)
RBS/ds Ralph B. Sewell Nuclear Licensing Administrator
~
(~-
C*.
)
RESPONSE TO IE BULLETINS NO 75-04 AND NO 75-04A Big Rock Point and Palisades May 23, 1975 IE Bulletin No 75-04
\\
- 1. Information Requested:
"Review.your overall procedures and system for controlling construction activities that interface with reactor operat-ing activities, with particular attention to the installation and testing of seals for electrical cables between compartments of the reactor building, eg, control room to cable spreading room."
Response
Refer to responses for No 2 and No 3, IE 75-04A.
- -- 2
- Information Requested:
"Review the design of floor and water penetra-
. tions seals, with particular attention to the flammability of' materials.
11
Response
The design of' floor and wall penetration seals have been re-viewed.
The materials specif'ied f'or use in these seals is consistent with Nuclear Mutual Limited Property Loss Protection Standards.
At the Palisades Plant, the review has shown that some seals were not installed in locations specif'ied on plant construction drawings and that where some seals were installed, they contain holes due to the addition or deletion of electrical cables. Materials have been.procured and received, with the exception of Fla.memastic, which was lost in shipment and is being tra~eds to properly install the def'icient seals.
This is expected to be completed by the end of June 1975.
At Big Rock Point, essentially no seals were provided in design and.con-struction.
We have reviewed this design and concluded that it is desirable to install seals for cable penetrations through the floor of the control room and the wall between the air compressor and cable penetration room.
A schedule is presently being developed for this installation.
- 3.
Information Requested:
"EValuate your procedures for the control of igni-tion sources which may be used for leak testing or other purposes in areas containing flammable materials."
Response
Policies with respect to control of ignition sources have been reviewed as indicated under Item 3, IE Bulletin 75-04A.
In essence, the*
only use of leak testing equipment that.is an ignitionsource is the use of a halide torch to detect Freon leakage during special testing conducted.
. by maintenance personnel.
This is an extremely infrequent undertaking and is used, for example, to check the leak tightness of the contaipment pressure test equipment (reference system) no more frequently than biannually.
IE Bulletin No 75-04A
- 2.
Information Requested:
Review your policies related to construction or maintenance and modification work to assure that activities which might affect the safety of a unit in operation, including the ability to shut
(_,
C '
~
down and cool the unit, are properly controlled.
Your review should con-sider particularily your policy on deferring construction, maintenance or modification work on a unit until a shutdown period except for emergency maintenance vital to continue safe operation or a safe shutdown of the unit."
Response
Consumers Power Company has reviewed its practices relating to construction or maintenance and modification work being performed while a unit is in operation. It has been our practice in the past and will continue to be our practice in the future to evaluate the risks associated with performing a job with the unit in operation. If there is a significant risk that the safety of a unit in operation, including the ability to shut down and cool a unit, would be jeopardized, a job would be deferred until a shutdown period.
In ther..absence of significant risk, jobs have been and will in the future be undertaken during either operation of the unit or shutdown.
In summary, we feel that many jobs can be performed during operation of a unit without significantly affecting the safety of operation of the unit.
Requiring that all jobs except emergency mainte-nance be performed with the unit shut down would be unduly restrictive.in that, for both o;irr units, a significant ;Loss of generation would be experienced without a significant reduction in the risk to public health and safety.
- 3.
Information Requested:
"Review your policies and procedures to assure that for construction or modification and maintenance activities during plant operation, particular attention is given to the following areas:
- a.
The degree of safety significance of affected and nearby cabling and
- piping.
- b.
The use and control of combustible materials.
- c.
The use and control of equipment that may be an ignition source.
- d.
The assignment of personnel knowledgeable of plant arrangement and plant operations, whose sole temporary responsibility ip monitoring the safe performance of construction or maintenance and modification work, including attention to otherwise unattended areas. adjacent to work areas * "
Response
Prior to assigning any maintenance or minor modification work, plant supervisors evaluate the job in terms of its potential effects on nearby equipment and for fire hazards.
For major modifications, a staff member is assigned to coordinate construction activities with the Company construction representative and the contractor.
This includes a review of the hazards in the areas that the contractor's men will be working to assure that they are aware of potential areas and activities that could have an effect on the safety of plant operation.
To provide greater assurance that plant staff members are performing these functions in a 2
. \\,
1*,.1
(
0.
i reasonable and effective manner, personnel involved will be required to review at least semiannually a listing of considerations that must be given to any job undertaken.
These considerations will include the ele-ments of Questions 2a, b, c and g of IE Bulletin 75-04A.
Consumers Power Company does not believe that the assignment of personnel with sole temporary responsibility for monitoring the safe performance of work would be as effective as our present system.
We believe that the safe performance can best be carried out by the supervisor directly in charge of the work.
To assign these responsibilit~es to an individual other than the supervisor in charge of the work would dilute the responsi-bility for safe work performance and.not alter the risk associated with a unit operation.
3e.
Information Requested:
"Provision of installed or portable equipment to provide the monitoring personnel with prompt communication with the oper-ation staff in the control room."
Response
We have reviewed the installed communication equipment and con-clude that it is adequate to provide prompt communication with the operat-ing staff in the control room from any on-site location. All plant personnel are familiar with the use of this equipment.
There is some question as to whether construction forces are familiar with the use of this equipment.
In the future, construction forces will be indoctrinated in the use of this equipment prior to performing work on site.
3f.
Information Requested:
"Provision of adequate fire prevention and fire suppression equipment, installed or portaqle,.for the following locations:
(l) Areas where work is bei~g_performed.
(2)
Areas where occurrence of fire has high safety significance even though the probability of occurrence is relatively small. 11
Response
The review for adequacy of fire prevention and fire suppression equipment has been completed at Big Rock Point and we have concluded that some equipment could be improved.
Thus, we are further reviewing the possibility of installing some fire detection and suppression equipment in the vicinity of the containment electrical penetrations.
This review has not yet been completed at Palisades.
3g.
Information Requested:
"Recognition that a fire, even one involving electrical equipment, may, if of sufficient intensity, require water as the ultimate suppression medium."
Response
Based on discussions with plant employees, we have determined that some did not understand that water could be used on electrical fires without risk of shock to the fire fighters.
An instruction package re-garding this subject is being prepared to provide plant personnel with instruction in the elements of fire fighting.
3
I
\\,
(
- 4.
Information. Reguested:
"Review your emergency procedures to assure con-siderations for alternate methods for accomplishing an orderly plant shutdown and cooldown are provided in case of loss of normal and preferred alternatives shutdown and cooldown systems for any reasons (eg, a fire).
In this connectiqn, assure that the minimum information necessary to assist the operators in such shutdown action, the minimum protection sys-tem actions required (eg, scram) and the spectrum of alternative paths available to the operators to supply cooling water and remove decay heat (dependent on plant conditions) are included in your emergency procedures."
Response
The Palisades Plant staff is developing a Loss of Control Procedure.
The Big Rock Point Plant staff review revealed that their emergency procedures are adequate.
4