ML19270H322
| ML19270H322 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 06/22/1979 |
| From: | Bixel D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Ziemann D Office of Nuclear Reactor Regulation |
| References | |
| TASK-02-04.D, TASK-05-02, TASK-05-03, TASK-05-08, TASK-06-07.B, TASK-06-07.C3, TASK-06-07.D, TASK-06-07.E, TASK-07-06, TASK-2-4.D, TASK-5-2, TASK-5-3, TASK-5-8, TASK-6-7.B, TASK-6-7.C3, TASK-6-7.D, TASK-6-7.E, TASK-7-6, TASK-RR NUDOCS 7906260194 | |
| Download: ML19270H322 (3) | |
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o......, o,..<.. - m.., o < ~,..,... ~.. s.~.em. o,c ~ o., -.... c~. e, 7 7,,,, m so June 22, 1979 Director, Nuclear Reactor Regulation Att Mr Dennis L Ziemann, Chief Operating Reactors Branch No 2 US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT - COMMENTS CONCERNING TOPICS DELETED FROM SEP REVIEW NRC letter, dated April 16, 1979, forwarded a list of SEP topics which are to be deleted from consideration for Big Rock Point either because they are addressed by other ongoing NRC review efforts or are not applicable due to Big Rock Point design features.
Consumers Power Company was requested to review this list and provide any comments for NRC consideration.
Consumers Power Company's comments on the proposed topic deletions are forwarded as an attachment to this letter.
David A Bixel (Signed)
David A Bixel Nuclear Licensing Administrator 2318 211 CC JGKeppler, USNRC 7 90626 0 Nf
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1 Consumers Power Company Comments on Topics To Be Deleted From SEP Review for Big Rock Point 1.
Topic VII-6, " Frequency Decay" has been deleted because it will be considered in ongoing NRR generic efforts.
The definition of this topic indicates that the safety objective is to ensure that reactor coolant flow will not decrease below that assumed for a reactor coolant pump flywheel coast down due to frequency decay.
Big Rock Point recirculating pump design does not include a flywheel. Accordingly, this topic is not applicable to Big Rock Point either as an SEP topic or as part of a generic NRR review.
2.
Topic VI-7.B, "ESF Switchover From Injection to Recirculation" was deleted because it is considered a PWR safety topic.
Switchover from injection of fire system water to recirculation is performed manually at Big Rock Point. Accordingly, this topic should be included in Big Rock Point's review.
System design is such that switchover is not required until many hours after the accident, thereby affording adequate time for operators to take the required action.
3.
Topic VI-7.D, "Long Term Cooling Passive Failures (eg, Flooding of Redundant Components)" was deleted because it is considered a PWR safety topic.
Redundant components of Big Rock Point's long-term cooling system are physically located in the same areas.
For example, the two core spray pumps are located in the same room and could be lost in the highly unlikely event the room were to be flooded.
Accordingly, this topic should be considered for Big Rock Point.
4.
Topic VI-7.C.3, "PWR Loop Isolation Valve Closure" was deleted because it is considered a PWR topic.
Big Rock Point has external recirculation loops incorporating valves to isolate the recirculating pumps.
Accordingly, this topic should be considered for Big Rock Point.
5.
Topic VI-7.E, "ECCS Sumn Design" was deleted because it was considered not applicable to Big P. ux Point design.
Long-term cooling at Big Rock Point involves recirculation of water from the containment building via the building sump. Accordingly, this topic should be considered for Big Rock Point.
6.
Topic II-4.D, " Stability of Slopes' should also be deleted from consideration for Big Rock Point since there are no appreciable slopes near the plant.
7.
Topic V-3, "Overpressurization Protection" was deleted because it is considered a PWR topic.
Big Rock Point has positive displacement control rod drive pumps which are used in performing hydrostatic tests.
Thus, the possibility of overpressurization in violation of Technical Specification NDT requirements exists. Accordingly, this topic should be considered for Big Rock Point.
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2 8.
Topic XV-2, " Spectrum of Steam System Piping Failures Inside and Outside of Containment (PRW)" was deleted because it addresses PWR concerns.
Consumers Power Company agrees that the definition of this topic implies concerns unique to PWRs.
However, some of the safety objectives involved with this topic, most notably the off-site dose concerns, could also be applicable to BWRs.
9.
Topic XV-8, " Control Rod Misoperation (System Malfunction or Operator Error)" is listed as a PWR topic.
The reference for this topic (Standard Review Plan 15.4.3) implies that current modes of BWR control rod operation make this concern inapplicable to BWRs.
Consumers Power Company notes that significant differences exist between the control rod operating mode used at Big Rock Point and that used by " current" BWRs.
Specifically, Big Rock Point has far fewer control rods than newer BWRs and does not have a Rod Block Monitor or Rod Worth Minimizer.
Consumers Power Company recommends that deletion of this topic for Big Rock Point be reconsidered in light of these differences.
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