ML20004A994
| ML20004A994 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 05/19/1981 |
| From: | Withrow G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8105270084 | |
| Download: ML20004A994 (9) | |
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consumers il Power N.
Company N.
General Offkes: 212 West MichlBan Avenue, Jackson, MI 49201 e (517) 788 0550 May 19, 1981 D
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]23'u.4, Dop eg Director, Nuclear Reactor Regulation i
Att Mr Dennis M Crutchfield, Chief
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Operating Reactors Branch No 5 O.s\\'g' US Nuclear Fegulatory Concission y
Washington, DC 20555 DCCKET 50-155 - LICENSE DFR BIG ROCK POINT PLA'iT - FIRE PROTECTIC" MODIFICATIOU3 NEC Generic Letter 81-12, dated Februar/- 20, 1931 requested information per-taining to proposed modificetions for compliance with the Fire Protection Rule (L5 FR 76602, November 19, 1980).
Consumers Power Com;Iny letter dated March 19, 1931 provide.f plans for a:hieving compliance with those requirements including a design description. The lesign of the Big Rock Foint Plant which utili: as an emergency condenser for plant shutdown,'.n the event of loss of AC povt.r provides an uncomplicated solution for providing the required alternate shutdown capability. The previously sub-mitted design description provides the specifies of how the energency conden-ser and alternate shutdown capability interface. Attach-ents 1 and 2 provided herein respon2 to the detailed information requests of Enclosures 1 and 2 to Geaeric Letter 81-12.
Gregory C Withrov (Signed)
Gregory C Withrov Senior Licensing Engineer CC Director, Region III, USURC URC Resident Inspector - Big Rock Point Attachments - 8 paces 8185270084
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i Big Rock Point Plant Fire Protection Modifications Response to Enclosure 1, Paragraph 8, Information Requirements of Generic Letter 81-12 dated February 20, 1981 1
8.
(a) Description of the systems or portions thereof used to provide the shutdown capability and modifications required to achieve the alternate shutdown capability if required.
Response: The description of the modifications for the assurance of safe shutdown - required by 10CFR50, Paragraph 50.h8 - was submitted by Consumers Power Company letter dated March 19, 1981. Subsequent I
to the submittal of thi description, a change in the planned modi-fication has been made which affects the normal power supply to Control Rod Drive (CRD) Pump #1.
This pump vill be supplied from its present source via a feeder cable routed through the equipment i
lock. On the outside of containment and the lock at or near the electrical penetration, a dual, interlocked, nonautomatic circuit i
breaker vill be installed. The breaker vill switch the motor to either its normal source or an alternate source. Attached Figure
- 1 illustrates this concept. See also response to 8(1).
i 8.
(b) System design by drawings which show normal and alternate shutdown i
control and power circuits, location of components, and that viring which is in the area and the viring which is out of the area that required the alternate system.
f Response: The information provided by 8(a) above and in our letter dated l
March 19, 1981 describe the modification design and by either descriptien or illustration provide the requested information.
8.
(c) Demonstrate that changes to safety systems vill not degrade safety systems.
(eg., new isolation switches and control switches should meet design criteria and standards in FSAR for electrical equipment i
inthe system that the switch is to be installed; cabinets that the switches are to be mounted in should also meet the same criteria (FSAR) as other safety related cabinets and panels; to avoid inad-vertent isolation from the control room, the isolation switches should be keylocked, er alarmed in the control room if in the l
" local" or " isolated" position; periodic checks should be made to verify switch is in the proper position for normal operations; and a single transfer switch or other new device should not be a source j
for a single failure to cause loss of redundant safety systems).
Response
1 Equipment and equipment housings procured for and utilized in the modifications for the assurance of the ability to take the plant to safe shutdown have been specified to be qualified for earthquakes in accordance with IEEE 3hh-1975 and IEEE 323-197h when placed within or interfacing with safety systems.
l 2 Switches which transfer control or instrument functions from the control room to the auxiliary shutdevn control station alarm in the control room when the devices in the auxiliary shutdown control station are enabled. See also response to 8(a).
2 3
The control functions transferred to the auxiliary shutdown control station are those for the emergency condenser outlet valves MO 7052 and MO 7062, the main steam isolation valve MO 7050, and the fire water rake-up to the emergency condenser SV h9h7 The control system of each valve vill be individually transferred. The two heat exchanger tube bundles of the emer-gency condenser are redundant. In the event of a failure of the transfer switch in the outlet valve control, only the operation of the valve associated with that transfer switch will be affected. Were the transfer switch for the main steam isolation valve to fail in transferring control to the auxiliary shutdown control station, it is possible the valve could not be closed and a consequence of this failure could result in the need to provide make-up to the reactor coolant system sooner if the valves downstream from the main steam isolation valve did not close tightly. If the transfer switch for the fire water make-up to the emergency condenser vere to fail and the valve could not be operated electrically from either control location, then the valve con be opened manually at the valve.
8.
(d) Demonstrate that viring, including power sources for the control circuit and equipment operation for the alternate shutdown method, is indepen-dent of equipment viring in the area to be avoided.
Response: The pcVer supply, actuatins devices, controls and other supporting equipment for achieving h9t shutdown are located in the core spray equipment room (which is celow the fuel cask unloading dock) or the stair rell outside the core spray equipment room. These two areas are below grade and completely separated frem the fire areas of concern.
See attached Drawing M100 - Equipment Location - plan above grade.
8.
(e) Demonstrate that alternate shutdown power sources, including all breakers, have isolation devices on control circuits that are routed through the area to be avoided, even if the breaker is to be operated manually.
Response: The information provided by 8(a) and 8(d) above provide the requested information.
8.
(f) Demonstrate that licensee procedure (s) have been developed uhich describe the tasks to be performed to effect the shutdown method.
A summary of these procedures should be submitted.
Response: Procedures vill be prepared for taking the plant to hot shttdown via the auxiliary rhutdown control station in the event a fire prevents the use of the main feedvater condenser system and the use of the emergency ccndenser from the normal control location - the control room. These procedures vill be finalized when the detailed design documents are completed and vill be implemented, including appropriate training, prior to operation of the facility with the completed fire protection modifications declared operdble, l
3 8.
(g) Demonstrate that spare fuses are available for control circuits where these fuses may be required in supplying power to control circuits used for the shutdown method and may be blown by the effects of a cable spreading room fire. The spare fuses should be located convenient to the existing fuses. The shutdown pro-celure should inform the operator to check these fuses.
Response: Spare fuses will be provided for equipment operable from the auxiliary shutdown control station.
8.
(h) Demonstrate that the manpower required to perform the shutdown functions using the procedures of (f) as well as to provide fire brigade members to fight the fire is available as required by the fire brigade technical specifications.
Response: By Technical Specifications, two members of the minimum shift crev that are excluded from the fire brigade are required to be on site at all times. These two members provide adequate manpower to safely shut the plant down from either the control room or the safe shut-down area.
8.
(i) Demonstrate that adequate acceptance tests are performed. These should verify thac: equipment operates from the local control station when the transfer or isolation switch is p1 teed in the
" local" position and that the equipment cannot be operated from the control room; and that equipment operates from the centrol room but cannot be operated at the local control station when the transfer or isolation switch is in the "reacte" position.
Response
Preoperational tests (acceptance tests) are required for all modifi-cations. The required tests vill incorporate the above criteria.
8.
(j) Technical Specifications of the curveillance requirements and limit-ing conditions fcr operation for that equipment not already covered by existing Technical Specifications.
For example, if new isolation and control suitches are added to a service water system, the exist-ing Technical Specifications surveillance requirements on the service water system should add a statement similar to the following:
"Every third pump test should also verify that the pump starts from the alternate shutdown station after moving all service water system isolation switches to the local control position."
Respc;;c: Technical Specifications will be submitted which require the demon-stration of the operability of the emergency condenser outlet, the main steam isolation and the emergency condenser fire water make-up valves independently both from the control room and the auxiliary shutdown control station each refueling outage.
h 8.
(k) 9emonstrate that the systems available are adequate to perform the necessary shutdown functions. The functions required should be based on previous analyses, if possible (eg., in the FSAR),
such as a loss of normal ac power or shutdown on a Group I isola-tion (BWR).
The equipment required for the alternate capability should be the same or equivalent to that relied on in the above analysis.
Response: The systems and equipment described in response to 8(a) for per-forming the shutdown functions when a fire is postulated in the specified areas of the plant are the same systems and equipment that are normally used for reactor coolant inventory control when in the hot standby operation and for the cold shutdown operation.
The emergency condenser is the ultimate heat sink on loss of off-site power.
8.
(1) Demonstrate that repair procedures for cold shutdown systems are developed and material for repairs is naintained on site.
Response: D ergency power for CRD Pump #1 vill be supplied from the diesel generator.
Because other contingency operations vill require operation of a CRD pump within a short time of their onset, a length of suitable sized cable vill be stored for connecting the diesel generator to the CRD pump motor feeder transfer switch near the equipment lock.
In the event fire damage precludes use of a reactor cooling water pump or a shutdown pump in its normal fashion, then one motor of each type of pump will be disconnected from its damaged feeder and connected to circuit breaker connected to a power feed cable permanently connected through containment via the equipment lock.
See document referenced in 8(a) above. The exterior end of the feeder cable vould then be connected to the emergency generator or to s h80V aource connected to present 2h00V station power source in the substation.
The emergency condenser is capable of supporting the het shutdown operation indefinetely, provided make-up water from the fire system to the shell of the condenser is available. However, shutdown cool-ing can be provided within two days considering the common availabil-ity of electrical cable and transformers (from within Consumers Power Company and/or from cottercial electrical equipment and materials suppliers) as needed to install a temporary h80V power source connected to the power feeder through containment for the shutdown cooling system.
Since there are many options for providing this emergency power source, the most suitable and most expeditious would be selected at the time of this contingency, if it ever occurs. Because of their ready availa-bility, materials and equipment vill not be obtained and stored in advance.
Big Rock Point Plant Fire Protection Modifications Response to Enclosure 2 Infonnation Req 11raments of Generic Letter 81-12 dated February 20, 1981 1.
(a) Provide a table that lists all equipment including instrumentation and support system equipment that are required by the alternative or dedicated method of achieving and maintaining hot shutdown.
Response
1.
Systems controlled from the auxiliary shutdown control station:
a.
D ergency Condenser 2.
Equipment controlled from the auxiliary shutdown control station:
Emergency condenser outlet valves M07052 & M07062.
a.
b.
Main steam isolation valve M07050.
Fire water make-up to emergency condenser SVh9h7.
c.
3.
Instrumentation systems displayed at the auxiliary shutdown control station:
a.
Steam drum level.
b.
Steam drum pressure.
c.
Emergency condenser low-level alarm.
d.
Battery and battery charger off-normal alarm.
1.
(b) For each alternative shutdown equipment listed in la above, provide e table t..st lists the essential cables (instrumentation, control and power) that sre located in the fil-: area.
Responre: The control circuits of the equipment listed under la2 above from the transfer switches located in the auxiliary shutdown control station to the control switches located in the control room are routed through the fire area.
j 1.
(c) Provide a table that lists safety related and non-safety related cables l
associated with the equipment and cables constituting the alternative or dedicated method of shutdown that are located in the fire area.
Response: The power source, the controls and the electrical circuitry of tne emergency condenser inlet valves are located in one or more of the fire areas.
1.
(d) Show that fire-induced failure of the cables listed in b and e above vill not prevent operation or cause maloperation of the alternative or dedicated shutdown method.
1 Response: Fire damaged control circuity of the equipment described in 1b above vill be disconnected by operation of the transfer switch which, at the same time, enables the auxiliary shutdown. control station control switches.
Fire damage and consequential closing of the emergency condenser inlet valves vill be prevented by removing operating power from the valves,
2 after checking the valves open prior to reactor operation. This vill be implemented by an addition to the operating procedures similar to the requirement for removing the operating power from the shutdown cooling system valves M07056, 7057, 7058 and 7059 Additional information describing system interactions is provided by which responds to Enclosure 1 of Generic Letter 81-12.
1.
(e) For each cable listed in 1b above, provide detailed elect.fcal schematic drawings that show how each cable is isolated from the fi:e area.
Response: The requested information is provided by ld above and Figure 1 of Consumers Power Company submittal dated March 19, 1981.
2.
(a) Identify each high-low pressure interface that uses redundant electrically control:ed devices (such as two series motor operated valves) to isolate or preclude rupture of any primary coolant boundary.
(b) Identify the device's essential cablin'g '(pover and control) and describe the cable routing (by fire area) from source to termination.
(c) Identify each location where the identified cables are separated by less than a vc11 having a three-hour fire rating from cables for the redundant device.
(d) For the areas identified in item 2c above (if any), provide the bases and justification as to the acceptability of the existing design or any proposed modifications.
Response: The single system containing redundant electrically controlled valves at the interface of high and low pressure syste=s is the shutdown system.
Existing operating procedures require electrical power for these valves to be disconnected prior to raising the pressure of the reactor coolant system.
(See CPCo letter DAbixel to DLZiemann, dated March 26, 1979.)
The cleanup system does present an additional interface of high and low pressure systems during resin sluicing from the cleanup deminer-alizer.
This interface is not considered a significant problem because resin sluicing ir an operstor attended action and only occurs on the order of twice per year daring reactor operation for a period of approximately four hours each. Ther? fore, the interface creating the potential problem occurs so inftequently that it is not considered necessary to address. It should be noted that one of the valves at each of the interfaces is pneumatically controlled and that the postu-lated electrical failure is associated with its closure signal which is received from an electrical pressure indicator in the cleanup demineralizer or the Containment Isolation System.
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