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| | issue date = 10/28/1985 | | | issue date = 10/28/1985 |
| | title = Requests Approval to Install Switches to Isolate Certain Remote Control Circuits to Ensure post-fire Alternate Shutdown Capability for Compliance w/10CFR50.48 & App R.Fee Paid | | | title = Requests Approval to Install Switches to Isolate Certain Remote Control Circuits to Ensure post-fire Alternate Shutdown Capability for Compliance w/10CFR50.48 & App R.Fee Paid |
| | author name = KUEMIN J L | | | author name = Kuemin J |
| | author affiliation = CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), | | | author affiliation = CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), |
| | addressee name = | | | addressee name = |
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| {{#Wiki_filter:*" consumers Power company ! i General Offices: 1945 West Parnell Road, *Jackson, Ml 49201 * {517) 1aa-osso October 28, 1985 Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 -LICENSE DPR-20 -PALISADES PLANT -REQUEST FOR APPROVAL TO INSTALL ISOLATION SWITCHES -COMPLIANCE WITH 10CFR50.48 AND APPENDIX R 10CFR50.48, Paragraph c.5 requires that design descriptions of modifications which affect alternate shutdown capability be submitted for prior review and approval. | | {{#Wiki_filter:! |
| In the process of complying with that requirement, Consumers Power Company, in the June 19, 1985 fire protection submittal, committed to submit detailed drawings of the location of isolation switches installed in the control .circuits of essential safe shutdown equipment. | | i consumers Power company General Offices: 1945 West Parnell Road, *Jackson, Ml 49201 * {517) 1aa-osso October 28, 1985 Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - |
| The schematic drawings and design description contained in Attachment I furnish the necessary detail to perform a design review and are being submitted in lieu of detailed drawings. | | REQUEST FOR APPROVAL TO INSTALL ISOLATION SWITCHES - |
| Attachment I provides the design description of switch tions which may be necessary for the isolation of certain remote control circuits and thereby to ensure post-fire alternate shutdown capability. | | COMPLIANCE WITH 10CFR50.48 AND APPENDIX R 10CFR50.48, Paragraph c.5 requires that design descriptions of modifications which affect alternate shutdown capability be submitted for prior review and approval. In the process of complying with that requirement, Consumers Power Company, in the June 19, 1985 fire protection submittal, committed to submit detailed drawings of the location of isolation switches installed in the control .circuits of essential safe shutdown equipment. The schematic drawings and design description contained in Attachment I furnish the necessary detail to perform a design review and are being submitted in lieu of detailed drawings. Attachment I provides the design description of switch installa-tions which may be necessary for the isolation of certain remote control circuits and thereby to ensure post-fire alternate shutdown capability. |
| Therefore, prior review and approval of these switches is required. | | Therefore, prior review and approval of these switches is required. |
| Furthermore, the installation of isolation switches in the control circuits of certain safety equipment has been determined to be an unresolved safety tion as defined in Section a.2. of lOCFRS0.59 by the Palisades Plant Review Committee. | | Furthermore, the installation of isolation switches in the control circuits of certain safety equipment has been determined to be an unresolved safety ques-tion as defined in Section a.2. of 10CFRS0.59 by the Palisades Plant Review Committee. Pursuant to 10CFR50.59 Section 2.c, Attachment I and II together provide a full description of the desired change and a safety analysis. |
| Pursuant to 10CFR50.59 Section 2.c, Attachment I and II together provide a full description of the desired change and a safety analysis. | | Engineering associated with these isolation switches has recently been com-pleted and installation is scheduled to begin as soon as NRC approval is received. Since the installation of these switches must be completed before plant startup from the upcoming refueling outage (startup is planned for mid |
| Engineering associated with these isolation switches has recently been pleted and installation is scheduled to begin as soon as NRC approval is received. | | -------=-F-=e:.!:b~r-=u:.:a~ry_, 1986) your prompt attention to this matter is requested. |
| Since the installation of these switches must be completed before plant startup from the upcoming refueling outage (startup is planned for mid 1986) your prompt attention to this matter is requested. | | 1--e-s1_1_0_4-=o-1-=-4_9=-_-=e:-;~~A-;;-gg8;;;;--1!1 - -:;-:._,_-...: - :-,J RD~ |
| 1--e-s ---:;-:._,_--::--: | | * ADO~K 0 255 PDR , |
| ... -,J
| | F - . ... |
| * 0 PDR , F -. ... OC1085-0007B-NL02 I . . ' ' *Director, Nuclear Reactor Regulation Palisades Plant Isolation Switches October 28, 1985 A check in the amount of $150.00 is enclosed as required by 10CFR170.21. | | OC1085-0007B-NL02 |
| James L Kuemin Staff Licensing Engineer CC Administrator, Region III, USNRC NRC Resident Inspector | | |
| -Palisades OC1085-0007B-NL02 2 | | I . |
| FP1085-0007C-NL02 ATTACHMENT I Consumers Power Company Palisades Plant Docket 50-255 ISOLATION SWITCHES DESIGN DESCRIPTION OF THE INSTALLATION OF ISOLATION SWITCHES TO COMPLY WITH THE CRITERIA OF 10CFR50.4S AND APPENDIX R October 28; 1985 I. General ATTACHMENT I Palisades Plant DESIGN DESCRIPTION OF THE INSTALLATION OF ISOLATION SWITCHES TO COMPLY WITH THE CRITERIA OF 10CFR50.48 AND APPENDIX R Alternate safe shutdown capability depends on the transmission of I-1 electrical power from the 1-1 diesel generator to either a charging pump or a high pressure safety injection (HPSI) pump. In order to maintain an adequate margin of subcooling in the Primary Coolant System (PCS), the 1-1 diesel must start within 2.25 hours of the time offsite power is lost. Worst case assumption is that offsite power is lost simultaneously with reactor trip. In the Palisades electrical distribution system, when operating a 480V breaker, local control overrides a remote signal. Locally overriding a remote signal to the larger 2400 volt breakers is not as easily accomplished.
| | ' 2 |
| Because of breaker design, the magnitude of the power involved, and personnel safety, the remote signal must be isolated from the breaker before local control is accomplished. | | *Director, Nuclear Reactor Regulation Palisades Plant Isolation Switches October 28, 1985 A check in the amount of $150.00 is enclosed as required by 10CFR170.21. |
| For example, if a spurious trip signal from the remote circuit has caused the breaker to open, the only safe method of locally closing that breaker is to remove the trip signal by isolating it from the breaker. A Cable Spreading Room fire, a Control Room fire, a in the 590' ----------c*orr+/-dor-of-the-Auxi-1-ia*ry-Bu-i-ld-i-ng-or-an-Eng-ineer-ed-Saf.eguar.ds_Eanel | | cc/~ |
| _______ _ Room fire, could cause an open or a hot short in the remote control FP1085-0007C-NL02 I-2 circuits of equipment which must be operable in order to operate the diesel generator, transmit electrical power from the diesel generator to the lC bus, transmit power from the lC bus to a service water pump which cools the diesel generator, and to transmit power from the lC bus to either a charging pump or a HPSI pump which, in turn, is necessary to maintain pressure, reactivity control, and inventory in the PCS. The service water pump and the HPSI pump receive their power directly from the lC bus. The charging pump can receive 480V power from a source in the Cable Spreading Room or a source in the Turbine Room. (See attached Sketch No 1.) To ensure that malfunctions in control circuits will not cause the inoperability of the diesel generator or the breakers which must close to* transmit the required power, switches which will isolate the remote control circuits will be installed:
| | James L Kuemin Staff Licensing Engineer CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades OC1085-0007B-NL02 |
| A. In the control circuit for control of diesel generator 1-1. B. In the control circuit for speed control of diesel generator 1-1. C. In the control circuit of breaker 152-107 which connects diesel generator 1-1 to the 2400 V lC bus. D. In the control circuit of breaker 152-103 which conne.cts the lC bus to the service water pump P-7B. FP1085-0007C-NL02 I-3 E. In the control circuit of breaker 152-110 which connects the IC bus to Station Power Transformer No. 13, located. in the Turbine Room, which can be used to supply 480 volt power to charging pumps P-55 B and C. The isolation switches described in A and B above are to be located in the 1-1 Diesel Generator Room. The isolation switches described in C, D, and E will be located in the lC Switchgear Room. In the case of a worst case fire in the 590' corridor of the Auxiliary Building renders the charging pumps P-55B and P-55C inoperable, HPSI pump P-66B will be used for PCS pressure, reactivity, and inventory control. Neither the control nor power circuits for P-66B are located in the 590' corridor fire area. Therefore, no isolation switch is required in the remote control circuit of HPSI pump P-66B. II. Design Description A. Assumptions Basically, two types of "hot shorts" exist. One is the shorting of one wire to another wire. An example of this is illustrated in Figure 1. The other is the shorting of two wires in a circuit to two wires in another circuit and is ref erred to as a double "hot | | |
| ______________
| | ATTACHMENT I Consumers Power Company Palisades Plant Docket 50-255 ISOLATION SWITCHES DESIGN DESCRIPTION OF THE INSTALLATION OF ISOLATION SWITCHES TO COMPLY WITH THE CRITERIA OF 10CFR50.4S AND APPENDIX R October 28; 1985 FP1085-0007C-NL02 |
| _ FP1085-0007C-NL02 I-4 The first type of short, tbs single hot short, is protected against in the isolation circuit design. Isolation switches are located in control circuits such that they will remove the portion of the circuit which passes through the Cable Spreading Room, Control Room, 590' corridor, or Engineered Safeguards Panel Room. In addition, backup fuses are added to the local circuits to provide a redundant path of control power. The backup fuses are placed by the isolation switches, concurrent with remote circuit isolation, into the local control circuit. Therefore, not only will the isolation switches remove a portion of the faulted or potentially faulted circuit, they will also switch in redundant fuses and allow local operation of the equipment.
| | |
| This design is schematically presented in Figure 3. The double "hot short" was not protected against in this design because it is not a credible occurrence. | | I-1 ATTACHMENT I Palisades Plant DESIGN DESCRIPTION OF THE INSTALLATION OF ISOLATION SWITCHES TO COMPLY WITH THE CRITERIA OF 10CFR50.48 AND APPENDIX R I. General Alternate safe shutdown capability depends on the transmission of electrical power from the 1-1 diesel generator to either a charging pump or a high pressure safety injection (HPSI) pump. In order to maintain an adequate margin of subcooling in the Primary Coolant System (PCS), |
| This decision was based on several cable design features. | | the 1-1 diesel must start within 2.25 hours of the time offsite power is lost. Worst case assumption is that offsite power is lost simultaneously with reactor trip. |
| One cable carries the conductors (two or more) required for one circuit. The conductors are individually insulated and then are spirally bound within an outer jacket, thus the conductors are never in the same relative position with respect to the outer jacket. In order to have a double "hot short," the spiralled conductors carrying the required voltage and polarity would have to contact -------------'each-o.the.r-in-exac.t-lo.cations_._This_co.n.tac.t_wo.uld_no_t_o.nly_haY-.e_t_o. | | In the Palisades electrical distribution system, when operating a 480V breaker, local control overrides a remote signal. Locally overriding a remote signal to the larger 2400 volt breakers is not as easily accomplished. Because of breaker design, the magnitude of the power involved, and personnel safety, the remote signal must be isolated from the breaker before local control is accomplished. For example, if a spurious trip signal from the remote circuit has caused the breaker to open, the only safe method of locally closing that breaker is to remove the trip signal by isolating it from the breaker. |
| ______ _ FP1085-0007C-NL02 be one of exact-voltage and polarity, but it would also have to be the correct spiralled conductor in one cable with the correct spiralled conductor of another cable and neither conductor could contact the grounded cable tray or conduit. Based on the low probability of the concurrent occurrence of these events, the double "hot short" is considered incredible.
| | A Cable Spreading Room fire, a Control Room fire, a f~re in the 590' |
| This position is similar to the established NRC position that a 3-phase motor need not be protected against a 3-phase short. B. Design Description I-8 The installation of isolation switches results in modification of the control circuits for three breakers and Diesel Generator 1-1 and involves the installation of General Electric Type SBM Transfer Switches. | | ----------c*orr+/-dor-of-the-Auxi-1-ia*ry-Bu-i-ld-i-ng-or-an-Eng-ineer-ed-Saf.eguar.ds_Eanel________ |
| The GE Type SBM switches have two positions, "local" and "remote." When the switches are in the "remote" position, the control circuits will operate as they presently exist -allowing operation from the control room. When the switches are switched to "local" then all control circuits outside the local equipment panels will be electrically isolated. | | Room fire, could cause an open or a hot short in the remote control FP1085-0007C-NL02 |
| In all three breaker panels, backup control power fuses are added. These fuses remain isolated from the control circuits until the | | |
| _______ _ control power will be available for the required breaker operation.
| | I-2 circuits of equipment which must be operable in order to operate the diesel generator, transmit electrical power from the diesel generator to the lC bus, transmit power from the lC bus to a service water pump which cools the diesel generator, and to transmit power from the lC bus to either a charging pump or a HPSI pump which, in turn, is necessary to maintain pressure, reactivity control, and inventory in the PCS. The service water pump and the HPSI pump receive their power directly from the lC bus. The charging pump can receive 480V power from a source in the Cable Spreading Room or a source in the Turbine Room. (See attached Sketch No 1.) |
| FP1085-0007C-NL02 I-9 The panels involved in this project are Breaker Panel 152-103 for power to Service Water Pump 7B, Breaker Panel 152-107 -the Diesel Generator 1-1 Output Breaker, Breaker 152-110 for power to Station Power Transformer
| | To ensure that malfunctions in control circuits will not cause the inoperability of the diesel generator or the breakers which must close to* transmit the required power, switches which will isolate the remote control circuits will be installed: |
| # 13, Diesel Generator 1-1 exciter panel C22, and Diesel Generator 1-1 gauge panel G20. Identical isolation switches are used in each of the five panels. The switches have five contacts which are closed when the switch is in the "local" position and fifteen contacts which are closed when the switch is in the "remote" position.
| | A. In the control circuit for volta~e control of diesel generator 1-1. |
| The number of contacts actually used to i.solate or enable the remote and local controls is different for each panel as illustrated in Table 1. FP1085-0007C-NL02 I-10 TABLE 1 ISOLATION SWITCH CONTACT POSITION Contacts Contacts Used SEare Control Circuit Control Circuit Contact Switch Position Switch Position Panel No Position Local Remote Local Remote 152-103 Open 9 3 6 2 Closed 3 9 2 6 152-107 Open 8 2 7 3 Closed 2 8 3 7 152-110 Open 4 4 11 1 Closed 4 4 1 11 G-20 Open 14 2 1 3 Closed 2 14 3 1 C-22 Open 15 4 0 1 Closed 4 15 1 0 FP1085-0007C-NL02 1-11 As an added security measure, all five switches are equipped with unique removable handles. The handles are removed when the switch is in the "remote" position and the control circuits are operating normally.
| | B. In the control circuit for speed control of diesel generator 1-1. |
| The switch handles are designed to only fit these control isolation switches and the isolation switches are designed to prevent handles from other switches being used to make them operate. The switches can be moved to the "local" position only when the proper handles are inserted. | | C. In the control circuit of breaker 152-107 which connects diesel generator 1-1 to the 2400 V lC bus. |
| The handles can not be removed from the switch until the switch is placed back in the "remote" position.
| | D. In the control circuit of breaker 152-103 which conne.cts the lC bus to the service water pump P-7B. |
| Access to these unique handles is to be administratively controlled.
| | FP1085-0007C-NL02 |
| FP1085-0007C-NL02 FP1085-0007D-NL02 ATTACHMENT II Consumers Power Company Palisades Plant Docket 50-255 ISOLATION SWITCHES SAFETY ANALYSIS October 28, 1985 3 Pages ATTACHMENT II SAFETY ANALYSIS II-1 Consumers Power Company presents this evaluation of the hazards considerations involved with the installation of isolation switches in the remote control circuits of equipment essential for hot shutdown as defined by 10CFR50.48 and Appendix R. The installation has been determined to be an unresolved safety question by the Plant Review Committee at Palisades.
| | |
| The following analysis is pursuant to the requirements of 10CFR50.59, and 50.90; and will justify the.conclusion that the installation of isolation switches as described in Attachment I does not significantly increase the probability or consequences of an accident previously evaluated; create the possibility of a new or different kind of accident from an accident previously evaluated; or, involve a significant reduction in the margin of safety. Therefore, a prompt approval to install the described isolation switches is justified.
| | I-3 E. In the control circuit of breaker 152-110 which connects the IC bus to Station Power Transformer No. 13, located. in the Turbine Room, which can be used to supply 480 volt power to charging pumps P-55 B and C. |
| inoperable.
| | The isolation switches described in A and B above are to be located in the 1-1 Diesel Generator Room. The isolation switches described in C, D, and E will be located in the lC Switchgear Room. |
| Failure of--ari-isolat-ion
| | In the case of a worst case fire in the 590' corridor of the Auxiliary Building renders the charging pumps P-55B and P-55C inoperable, HPSI pump P-66B will be used for PCS pressure, reactivity, and inventory control. Neither the control nor power circuits for P-66B are located in the 590' corridor fire area. Therefore, no isolation switch is required in the remote control circuit of HPSI pump P-66B. |
| : swHcn, tion* after a worst case fire, can do nothing worse than make a piece of FP1085-0007D-NL02
| | II. Design Description A. Assumptions Basically, two types of "hot shorts" exist. One is the shorting of one wire to another wire. An example of this is illustrated in Figure 1. The other is the shorting of two wires in a circuit to two wires in another circuit and is ref erred to as a double "hot |
| * II-2 redundant safe shutdown equipment inoperable.
| | ------------shotct-.-"-~his-si.tua.tion-is-illustrated-in-Eigur.e_2_. _______________ |
| That is the same condition assumed during previously evaluated accident probabilities or consequences. (Note that except for Loss of Offsite Power, the single failure criteria need not be applied to fire scenarios.)
| | FP1085-0007C-NL02 |
| The switches involved are qualified to IEE-344-1975 and are the same type used throughout industry. | | |
| Installation and testing will meet the same codes and standards as used for other similarly classified equipment at Palisades.
| | I-4 The first type of short, tbs single hot short, is protected against in the isolation circuit design. Isolation switches are located in control circuits such that they will remove the portion of the circuit which passes through the Cable Spreading Room, Control Room, 590' corridor, or Engineered Safeguards Panel Room. In addition, backup fuses are added to the local circuits to provide a redundant path of control power. The backup fuses are placed by the isolation switches, concurrent with remote circuit isolation, into the local control circuit. Therefore, not only will the isolation switches remove a portion of the faulted or potentially faulted circuit, they will also switch in redundant fuses and allow local operation of the equipment. This design is schematically presented in Figure 3. |
| Therefore, Consumers Power Company concludes that the installation of tion switches as described in Attachment I does not significantly increase the probability or consequences of an accident previously evaluated.
| | The double "hot short" was not protected against in this design because it is not a credible occurrence. This decision was based on several cable design features. One cable carries the conductors (two or more) required for one circuit. The conductors are individually insulated and then are spirally bound within an outer jacket, thus the conductors are never in the same relative position with respect to the outer jacket. |
| The worst case failure of any or all of the switches installed, as described in Attachment I, can result in causing the 1-1 Diesel Generator, the lC 2400V bus, the P-7B Service Water Pump and the No. 13 Station Power Transformer to be inoperable.
| | In order to have a double "hot short," the spiralled conductors carrying the required voltage and polarity would have to contact |
| The inoperability of this equipment singularly or all at one time does not create the possibility of a new or different kind of accident, because redundant equipment is available.
| | -------------'each-o.the.r-in-exac.t-lo.cations_._This_co.n.tac.t_wo.uld_no_t_o.nly_haY-.e_t_o._______ |
| Therefore, no new or different kinds of accident from any accident previously evaluated is created. Redundant equipment, whose function is not affected by the failure or bility of the newly installed switches, is available to maintain the margin of safety associated with the effected systems. The probability of malfunction or failure of the new switches is small during the time that redundant equip-ment may be inoperable:--Tlie time fliat-tnis be inoperable during plant operation is also restricted by the Technical FP1085-0007D-NL02
| | FP1085-0007C-NL02 |
| * II-3 Specifications.
| | |
| Switch design and the standards to which each is installed and tested result in a very reliable switching operation.
| | I-8 be one of exact-voltage and polarity, but it would also have to be the correct spiralled conductor in one cable with the correct spiralled conductor of another cable and neither conductor could contact the grounded cable tray or conduit. |
| Therefore, the amount of reduction in the margin of safety due to the* postulated failure of these switches is considered very small. The overall increase in the margin of safety due to the ability to quickly isolate remote controls after or during a worst case fire may have a more significant effect. The overall margin of safety, therefore, may have a net increase; or if it is reduced, is reduced by an insignificant amount. FP1085-0007D-NL02}}
| | Based on the low probability of the concurrent occurrence of these events, the double "hot short" is considered incredible. This position is similar to the established NRC position that a 3-phase motor need not be protected against a 3-phase short. |
| | B. Design Description The installation of isolation switches results in modification of the control circuits for three breakers and Diesel Generator 1-1 and involves the installation of General Electric Type SBM Transfer Switches. The GE Type SBM switches have two positions, "local" and "remote." When the switches are in the "remote" position, the control circuits will operate as they presently exist - allowing operation from the control room. When the switches are switched to "local" then all control circuits outside the local equipment panels will be electrically isolated. |
| | In all three breaker panels, backup control power fuses are added. |
| | These fuses remain isolated from the control circuits until the |
| | ------------~i-so+/-a-t-ion-swi-t:c-hes-a-~e-sw-i-tched-to__!..!.local.,~and_ens.ur.e_tha.t_lo_cal ________ |
| | control power will be available for the required breaker operation. |
| | FP1085-0007C-NL02 |
| | |
| | I-9 The panels involved in this project are Breaker Panel 152-103 for power to Service Water Pump 7B, Breaker Panel 152-107 - the Diesel Generator 1-1 Output Breaker, Breaker 152-110 for power to Station Power Transformer # 13, Diesel Generator 1-1 exciter panel C22, and Diesel Generator 1-1 gauge panel G20. |
| | Identical isolation switches are used in each of the five panels. |
| | The switches have five contacts which are closed when the switch is in the "local" position and fifteen contacts which are closed when the switch is in the "remote" position. The number of contacts actually used to i.solate or enable the remote and local controls is different for each panel as illustrated in Table 1. |
| | FP1085-0007C-NL02 |
| | |
| | I-10 TABLE 1 ISOLATION SWITCH CONTACT POSITION Contacts Contacts Used SEare Control Circuit Control Circuit Contact Switch Position Switch Position Panel No Position Local Remote Local Remote 152-103 Open 9 3 6 2 Closed 3 9 2 6 152-107 Open 8 2 7 3 Closed 2 8 3 7 152-110 Open 4 4 11 1 Closed 4 4 1 11 G-20 Open 14 2 1 3 Closed 2 14 3 1 C-22 Open 15 4 0 1 Closed 4 15 1 0 FP1085-0007C-NL02 |
| | |
| | 1-11 As an added security measure, all five switches are equipped with unique removable handles. The handles are removed when the switch is in the "remote" position and the control circuits are operating normally. The switch handles are designed to only fit these control isolation switches and the isolation switches are designed to prevent handles from other switches being used to make them operate. The switches can be moved to the "local" position only when the proper handles are inserted. The handles can not be removed from the switch until the switch is placed back in the "remote" position. Access to these unique handles is to be administratively controlled. |
| | FP1085-0007C-NL02 |
| | |
| | ATTACHMENT II Consumers Power Company Palisades Plant Docket 50-255 ISOLATION SWITCHES SAFETY ANALYSIS October 28, 1985 3 Pages FP1085-0007D-NL02 |
| | |
| | II-1 ATTACHMENT II SAFETY ANALYSIS Consumers Power Company presents this evaluation of the hazards considerations involved with the installation of isolation switches in the remote control circuits of equipment essential for hot shutdown as defined by 10CFR50.48 and Appendix R. The installation has been determined to be an unresolved safety question by the Plant Review Committee at Palisades. |
| | The following analysis is pursuant to the requirements of 10CFR50.59, and 50.90; and will justify the.conclusion that the installation of isolation switches as described in Attachment I does not significantly increase the probability or consequences of an accident previously evaluated; create the possibility of a new or different kind of accident from an accident previously evaluated; or, involve a significant reduction in the margin of safety. |
| | Therefore, a prompt approval to install the described isolation switches is justified. |
| | inoperable. Failure of--ari-isolat-ion swHcn, except-dur*1n-g-H*s-p-o-stfire-opera--.-------- |
| | tion* after a worst case fire, can do nothing worse than make a piece of FP1085-0007D-NL02 |
| | |
| | II-2 redundant safe shutdown equipment inoperable. That is the same condition assumed during previously evaluated accident probabilities or consequences. |
| | (Note that except for Loss of Offsite Power, the single failure criteria need not be applied to fire scenarios.) |
| | The switches involved are qualified to IEE-344-1975 and are the same type used throughout industry. Installation and testing will meet the same codes and standards as used for other similarly classified equipment at Palisades. |
| | Therefore, Consumers Power Company concludes that the installation of isola-tion switches as described in Attachment I does not significantly increase the probability or consequences of an accident previously evaluated. |
| | The worst case failure of any or all of the switches installed, as described in Attachment I, can result in causing the 1-1 Diesel Generator, the lC 2400V bus, the P-7B Service Water Pump and the No. 13 Station Power Transformer to be inoperable. The inoperability of this equipment singularly or all at one time does not create the possibility of a new or different kind of accident, because redundant equipment is available. Therefore, no new or different kinds of accident from any accident previously evaluated is created. |
| | Redundant equipment, whose function is not affected by the failure or opera-bility of the newly installed switches, is available to maintain the margin of safety associated with the effected systems. The probability of malfunction or failure of the new switches is small during the time that redundant equip-ment may be inoperable:--Tlie time fliat-tnis reoundant-e-quipment-ts-a-1.-lowed-to------- |
| | be inoperable during plant operation is also restricted by the Technical FP1085-0007D-NL02 |
| | * II-3 Specifications. Switch design and the standards to which each is installed and tested result in a very reliable switching operation. Therefore, the amount of reduction in the margin of safety due to the* postulated failure of these switches is considered very small. The overall increase in the margin of safety due to the ability to quickly isolate remote controls after or during a worst case fire may have a more significant effect. The overall margin of safety, therefore, may have a net increase; or if it is reduced, is reduced by an insignificant amount. |
| | FP1085-0007D-NL02}} |
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML18066A6871999-10-19019 October 1999 Forwards Response to NRC 990908 RAI Re Inservice Insp Program Relief Request 14.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6881999-10-19019 October 1999 Forwards Rev 5 to Palisades Nuclear Plant COLR, Per Requirements of TS 6.6.5.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6741999-10-0202 October 1999 Forwards MOR for Sept 1999 for Palisades Nuclear Plant & Operating Data Rept Sheet for Month of Aug 1999.MOR for Aug 1999 Inadvertently Had Copy of Ref Data Sheet for Apr 1999 Data ML18066A6791999-10-0101 October 1999 Provides Response to RAI Re Draft Rept, Study of Air- Operated Valves in Us Nuclear Power Plants. ML18066A6621999-09-30030 September 1999 Notifies NRC That Util Will Implement ITS at Plant on or Before Oct 31,2000 & Attachments 1 & 2 Contains Request for License Condition Which Relates First Performance of New or Revised Surveillance Requirements to Implementation of ITS ML18066A6601999-09-29029 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations. ML18066A6471999-09-17017 September 1999 Forwards Final Clean Copies of ITS & Bases Pages Which Incorporate All Changes Proposed in Listed Ltrs.Clean Copies Also Incorporate Some Editorial Changes & Bases Clarifications as Result of Ongoing Reviews to LCOs ML18066A6331999-09-0202 September 1999 Forwards Monthly Operating Rept for Aug 1999 & Revised Monthly Operating Rept for Apr 1999 for Palisades Nuclear Plant ML18066A6261999-08-26026 August 1999 Forwards Addl New Valve Relief Request as Alternative to Code Requirements That Will Provide Acceptable Level of Quality & Safety.Request Would Allow Use of App II, Check Valve Condition Monitoring Program, of ASME OM Code-1995 ML20211D5661999-08-17017 August 1999 Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d).Attachments 1 & 2 Summarize Test Results at Palisades Plant,Big Rock Point Plant & Corporate Ofc ML18066A6111999-08-13013 August 1999 Requests Exemption from Certain Requirements of 10CFR50,App R, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101. Request Concerns Oil Collection Sys Requirements for PCP Motors ML18066A5881999-07-30030 July 1999 Provides Rev to Instrument Channel Drift Measurement Submitted on 990611,in Response to NRC Comments on Util RAI Response for Sections 3.3,3.5 & 3.6 & Editorial Changes Revs Necessary for Consistency within ITS ML18066A5921999-07-30030 July 1999 Forwards Results of Review by Consumers Energy of Two NRC Draft Repts Entitled, Evaluation of Air-Operated Valves at Light-Water Reactors & Study of Air-Operated Valves in Us Nuclear Power Plants. ML18066A5971999-07-30030 July 1999 Forwards Markup of Draft NRC SE Re Util Proposal to Convert to Its.Ltr Contains No New Commitments & No Revs to Existing Commitments ML20210G8351999-07-29029 July 1999 Final Response to FOIA Request for Documents.Records in App a Encl & Will Be Available in PDR ML18066A5651999-07-19019 July 1999 Forwards Corrections to Previously Submitted TS Section 3.7, Plant Systems, Converting to Its,Per NUREG-1432.Licensee Realized That Certain Provisions of CTS Had Been Inappropriately Replaced with Provisions from STS ML18066A5111999-06-29029 June 1999 Provides Voluntary Confirmation of Facility Readiness as Outlined in GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Disclosure & Response Encl ML20209B2081999-06-29029 June 1999 Discusses Closure of Response to RAI Re GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity. Rvid,Version 2 Issued as Result of Review of Responses.Info Should Be Reviewed & Comments Submitted by 990901 ML20210G8791999-06-23023 June 1999 FOIA Request for All Document Communications Between NRC & Region III Involving R Landsman,B Jorgensen & R Caniano & NRC Staff Under Their Supervision & All Communications in Their Possession to & from Consumers Power Re Plant ML18066A5061999-06-17017 June 1999 Forwards Responses to NRC Questions for ITS LCOs 3.6.3 & 3.6.6 of 990126 Submittal.One Editorial Change in Addition to Those Made in Response to NRC Comments & Conforming Changes Made to Associated Bases,Encl ML18066A4991999-06-11011 June 1999 Forwards Responses to NRC Comments Re ITS Section 3.3 & Associated Revs to ITS Sections 1.0,3.3,3.4 & 3.9 of 990126 ITS Conversion Submittal.One Technical Change & Several Editorial Changes Unrelated to NRC Comments,Also Provided IR 05000255/19970181999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18066A4921999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18068A6011999-06-0808 June 1999 Forwards Description of Recent Changes Made to Palisades Site Emergency Plan,Excluding Minor & Editorial Changes Not Requiring Further Explanation ML18066A4881999-06-0404 June 1999 Provides Responses to NRC Questions & Associated Editorial Revs for ITS LCOs 3.6.1,3.6.2,3.6.4,3.6.5 & 3.6.7 of 980126 Submittal.Responses to Comments on Remaining Section 3.6 LCOs Will Be Submitted Separately ML18066A4801999-05-24024 May 1999 Forwards Copy of Rev to NPDES Permit Number MI0001457 Renewal Application as Submitted to Mi Dept of Environ Quality on 990513 ML18066A4721999-05-18018 May 1999 Informs That During Period from 981101-990430,there Were No NPDES Permit Violations & No Repts of Oil,Salt or Polluting Matl Losses Were Made to Govt Agencies ML18066A4651999-05-17017 May 1999 Forwards ISI Program Relief Request 14 for NRC Approval in Accordance with 10CFR50.55(a)(3) as Requirement for Which Proposed Alternative Provide Acceptable Level of Quality & Safety.Rev 0 to SIR-99-032 Rept Also Encl ML18066A4611999-05-14014 May 1999 Requests Approval to Use Alternative Requirements IAW 10CFR50.55a(a)(3)(i),proposing to Follow Requirements of ASME Boiler & Pressure Vessel Code Case N-566-1.IST Program Relief Request 6 for NRC Approval Encl ML18068A5831999-05-0303 May 1999 Forwards Proposed TS Section 3.5,in Response to NRC 990317 RAI Re Util 980126 TS Change Request Re Conversion to Improved Ts,Per NUREG-1432 ML20206J2411999-04-30030 April 1999 Submits Corrected Copy of Ltr Forwarding 1998 Consumers Energy Co Annual Rept. Ltr Contains Corrected Docket & License Number for Big Rock Point.With One Oversize Encl ML20217A8191999-04-29029 April 1999 Forwards Listed Matls Related to Palisades Plant June 1999 Initial License Exam ML20206E8271999-04-28028 April 1999 Forwards Palisades Plant Annual Radiological Environ Operating Rept for 1998. There Were No Reportable Events During This Period ML20207B4661999-04-23023 April 1999 Forwards Copy of Final Exercise Rept for Biennial Radiological Emergency Preparedness Exercise Conducted on 981201 for Palisades Npp.No Deficiencies Noted.Seven New Arcas Identified ML18066A4531999-04-0707 April 1999 Forwards ITS Pages 3.1.4-2 & 3.1.4-8,revising Completion Time for Action D.1,as Requested by NRC 990406 Telcon,Per TS Change Request Submitted 980126.Change Submitted Does Not Alter Conclusions of No Signficant Hazards Considerations ML18066A4481999-04-0202 April 1999 Responds to Violations Noted in Insp Rept 50-255/98-06. Corrective Actions:Nuclear Performance Assessment Dept Has Reviewed Observations & Agrees That Field Observations by Qualified Personnel Are Important Aspect of Program ML18066A4471999-03-30030 March 1999 Confirms Completion of Util Review of Design Engineering Contractor Cable Ampacity Evaluation.Evaluation Available at Plant for NRC Review ML18066A4411999-03-30030 March 1999 Forwards Response to NRC 990126 RAI Re TS Section 3.7 of Util 980126 LAR Request for Conversion to Its.Licensee Received Permission to Delay TS Section 3.6 Response to Allow for Addl Time for Preparation & Internal Review ML18066A4441999-03-26026 March 1999 Submits Certification of Financial Assurance for Decommissioning of Palisades Nuclear Plant.Certified Rept of Status of Consumers Energy Co Decommissioning Funding & Trust Agreement Encl as Attachments 1 & 2 ML18066A4401999-03-25025 March 1999 Forwards Revised Best Estimate Fluence Evaluation Using Industry Data, Providing Justification for Using Industry Data to Determine Best Estimate Fluence.Review of Info & SE Requested ML18066A4191999-03-23023 March 1999 Forwards 1998 Annual Radioactive Effluent Release & Disposal Rept, for Palisades Plant,Providing Summary of Quantities of Radioactive Liquid & Gaseous Effluent Releases & Solid Radioactive Waste Processed During 1998 ML18066A4231999-03-22022 March 1999 Forwards Answers to 990311 Telcon Request for Addl Clarification & Revs Re ITS Section 3.4.Markups of Previously Submitted TS Pages & Revised Pages for Section 3.4 Also Encl ML20204F2091999-03-18018 March 1999 Requests That Listed TS Change Requests (Tscrs) Be Issued with Allowance That Tscrs Be Fully Implemented within Sixty Days of Issuance.Request Will Allow Time for Completion of Final Training & Procedure Changes Associated with Amend ML18066A4121999-03-18018 March 1999 Concludes That Mod to Provide Automatic Switchover of Control Room Heating,Ventilation & Air Conditioning (CRHVAC) Sys to Emergency Mode Is Not Needed to Meet Regulatory Requirements.Mod Commitment Cancelled ML18066A4141999-03-18018 March 1999 Forwards Rev 4 to COLR, Containing Limits for Fuel Cycle 14 & Future Cycles ML20204E5861999-03-16016 March 1999 Submits Current Limits of Property Insurance Maintained at Consumers Energy Co Operating Nuclear Power Plants ML18066A4131999-03-11011 March 1999 Responds to NRC 990210 Ltr Re Violations Noted in Insp Rept 50-255/98-22.Corrective Actions:Analytical Evaluation, EA-C-PAL-98-1067-01, P-50A Case to Cover Stud Evaluation, Was Submitted to NRC on 981220 ML18068A5241999-02-12012 February 1999 Resubmits Relief Request 12,with Addl Info That Includes Specific Locations Where Relief Request Would Be Applied,Per 10CFR50.55a(g)(5)(iii) ML18068A5211999-02-11011 February 1999 Informs NRC That Implementation of Formal Industry Position on Severe Accident Mgt at Palisades Plant Was Completed on 981217 ML20203F2541999-02-10010 February 1999 Informs That Beginning 990216,DE Hills Will Be Chief of Operations Branch Which Includes Operator Licensing Function 1999-09-30
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML18066A6871999-10-19019 October 1999 Forwards Response to NRC 990908 RAI Re Inservice Insp Program Relief Request 14.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6881999-10-19019 October 1999 Forwards Rev 5 to Palisades Nuclear Plant COLR, Per Requirements of TS 6.6.5.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6741999-10-0202 October 1999 Forwards MOR for Sept 1999 for Palisades Nuclear Plant & Operating Data Rept Sheet for Month of Aug 1999.MOR for Aug 1999 Inadvertently Had Copy of Ref Data Sheet for Apr 1999 Data ML18066A6791999-10-0101 October 1999 Provides Response to RAI Re Draft Rept, Study of Air- Operated Valves in Us Nuclear Power Plants. ML18066A6621999-09-30030 September 1999 Notifies NRC That Util Will Implement ITS at Plant on or Before Oct 31,2000 & Attachments 1 & 2 Contains Request for License Condition Which Relates First Performance of New or Revised Surveillance Requirements to Implementation of ITS ML18066A6601999-09-29029 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations. ML18066A6471999-09-17017 September 1999 Forwards Final Clean Copies of ITS & Bases Pages Which Incorporate All Changes Proposed in Listed Ltrs.Clean Copies Also Incorporate Some Editorial Changes & Bases Clarifications as Result of Ongoing Reviews to LCOs ML18066A6331999-09-0202 September 1999 Forwards Monthly Operating Rept for Aug 1999 & Revised Monthly Operating Rept for Apr 1999 for Palisades Nuclear Plant ML18066A6261999-08-26026 August 1999 Forwards Addl New Valve Relief Request as Alternative to Code Requirements That Will Provide Acceptable Level of Quality & Safety.Request Would Allow Use of App II, Check Valve Condition Monitoring Program, of ASME OM Code-1995 ML20211D5661999-08-17017 August 1999 Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d).Attachments 1 & 2 Summarize Test Results at Palisades Plant,Big Rock Point Plant & Corporate Ofc ML18066A6111999-08-13013 August 1999 Requests Exemption from Certain Requirements of 10CFR50,App R, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101. Request Concerns Oil Collection Sys Requirements for PCP Motors ML18066A5971999-07-30030 July 1999 Forwards Markup of Draft NRC SE Re Util Proposal to Convert to Its.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A5881999-07-30030 July 1999 Provides Rev to Instrument Channel Drift Measurement Submitted on 990611,in Response to NRC Comments on Util RAI Response for Sections 3.3,3.5 & 3.6 & Editorial Changes Revs Necessary for Consistency within ITS ML18066A5921999-07-30030 July 1999 Forwards Results of Review by Consumers Energy of Two NRC Draft Repts Entitled, Evaluation of Air-Operated Valves at Light-Water Reactors & Study of Air-Operated Valves in Us Nuclear Power Plants. ML18066A5651999-07-19019 July 1999 Forwards Corrections to Previously Submitted TS Section 3.7, Plant Systems, Converting to Its,Per NUREG-1432.Licensee Realized That Certain Provisions of CTS Had Been Inappropriately Replaced with Provisions from STS ML18066A5111999-06-29029 June 1999 Provides Voluntary Confirmation of Facility Readiness as Outlined in GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Disclosure & Response Encl ML20210G8791999-06-23023 June 1999 FOIA Request for All Document Communications Between NRC & Region III Involving R Landsman,B Jorgensen & R Caniano & NRC Staff Under Their Supervision & All Communications in Their Possession to & from Consumers Power Re Plant ML18066A5061999-06-17017 June 1999 Forwards Responses to NRC Questions for ITS LCOs 3.6.3 & 3.6.6 of 990126 Submittal.One Editorial Change in Addition to Those Made in Response to NRC Comments & Conforming Changes Made to Associated Bases,Encl ML18066A4991999-06-11011 June 1999 Forwards Responses to NRC Comments Re ITS Section 3.3 & Associated Revs to ITS Sections 1.0,3.3,3.4 & 3.9 of 990126 ITS Conversion Submittal.One Technical Change & Several Editorial Changes Unrelated to NRC Comments,Also Provided IR 05000255/19970181999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18066A4921999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18068A6011999-06-0808 June 1999 Forwards Description of Recent Changes Made to Palisades Site Emergency Plan,Excluding Minor & Editorial Changes Not Requiring Further Explanation ML18066A4881999-06-0404 June 1999 Provides Responses to NRC Questions & Associated Editorial Revs for ITS LCOs 3.6.1,3.6.2,3.6.4,3.6.5 & 3.6.7 of 980126 Submittal.Responses to Comments on Remaining Section 3.6 LCOs Will Be Submitted Separately ML18066A4801999-05-24024 May 1999 Forwards Copy of Rev to NPDES Permit Number MI0001457 Renewal Application as Submitted to Mi Dept of Environ Quality on 990513 ML18066A4721999-05-18018 May 1999 Informs That During Period from 981101-990430,there Were No NPDES Permit Violations & No Repts of Oil,Salt or Polluting Matl Losses Were Made to Govt Agencies ML18066A4651999-05-17017 May 1999 Forwards ISI Program Relief Request 14 for NRC Approval in Accordance with 10CFR50.55(a)(3) as Requirement for Which Proposed Alternative Provide Acceptable Level of Quality & Safety.Rev 0 to SIR-99-032 Rept Also Encl ML18066A4611999-05-14014 May 1999 Requests Approval to Use Alternative Requirements IAW 10CFR50.55a(a)(3)(i),proposing to Follow Requirements of ASME Boiler & Pressure Vessel Code Case N-566-1.IST Program Relief Request 6 for NRC Approval Encl ML18068A5831999-05-0303 May 1999 Forwards Proposed TS Section 3.5,in Response to NRC 990317 RAI Re Util 980126 TS Change Request Re Conversion to Improved Ts,Per NUREG-1432 ML20206J2411999-04-30030 April 1999 Submits Corrected Copy of Ltr Forwarding 1998 Consumers Energy Co Annual Rept. Ltr Contains Corrected Docket & License Number for Big Rock Point.With One Oversize Encl ML20217A8191999-04-29029 April 1999 Forwards Listed Matls Related to Palisades Plant June 1999 Initial License Exam ML20206E8271999-04-28028 April 1999 Forwards Palisades Plant Annual Radiological Environ Operating Rept for 1998. There Were No Reportable Events During This Period ML20207B4661999-04-23023 April 1999 Forwards Copy of Final Exercise Rept for Biennial Radiological Emergency Preparedness Exercise Conducted on 981201 for Palisades Npp.No Deficiencies Noted.Seven New Arcas Identified ML18066A4531999-04-0707 April 1999 Forwards ITS Pages 3.1.4-2 & 3.1.4-8,revising Completion Time for Action D.1,as Requested by NRC 990406 Telcon,Per TS Change Request Submitted 980126.Change Submitted Does Not Alter Conclusions of No Signficant Hazards Considerations ML18066A4481999-04-0202 April 1999 Responds to Violations Noted in Insp Rept 50-255/98-06. Corrective Actions:Nuclear Performance Assessment Dept Has Reviewed Observations & Agrees That Field Observations by Qualified Personnel Are Important Aspect of Program ML18066A4471999-03-30030 March 1999 Confirms Completion of Util Review of Design Engineering Contractor Cable Ampacity Evaluation.Evaluation Available at Plant for NRC Review ML18066A4411999-03-30030 March 1999 Forwards Response to NRC 990126 RAI Re TS Section 3.7 of Util 980126 LAR Request for Conversion to Its.Licensee Received Permission to Delay TS Section 3.6 Response to Allow for Addl Time for Preparation & Internal Review ML18066A4441999-03-26026 March 1999 Submits Certification of Financial Assurance for Decommissioning of Palisades Nuclear Plant.Certified Rept of Status of Consumers Energy Co Decommissioning Funding & Trust Agreement Encl as Attachments 1 & 2 ML18066A4401999-03-25025 March 1999 Forwards Revised Best Estimate Fluence Evaluation Using Industry Data, Providing Justification for Using Industry Data to Determine Best Estimate Fluence.Review of Info & SE Requested ML18066A4191999-03-23023 March 1999 Forwards 1998 Annual Radioactive Effluent Release & Disposal Rept, for Palisades Plant,Providing Summary of Quantities of Radioactive Liquid & Gaseous Effluent Releases & Solid Radioactive Waste Processed During 1998 ML18066A4231999-03-22022 March 1999 Forwards Answers to 990311 Telcon Request for Addl Clarification & Revs Re ITS Section 3.4.Markups of Previously Submitted TS Pages & Revised Pages for Section 3.4 Also Encl ML20204F2091999-03-18018 March 1999 Requests That Listed TS Change Requests (Tscrs) Be Issued with Allowance That Tscrs Be Fully Implemented within Sixty Days of Issuance.Request Will Allow Time for Completion of Final Training & Procedure Changes Associated with Amend ML18066A4141999-03-18018 March 1999 Forwards Rev 4 to COLR, Containing Limits for Fuel Cycle 14 & Future Cycles ML18066A4121999-03-18018 March 1999 Concludes That Mod to Provide Automatic Switchover of Control Room Heating,Ventilation & Air Conditioning (CRHVAC) Sys to Emergency Mode Is Not Needed to Meet Regulatory Requirements.Mod Commitment Cancelled ML20204E5861999-03-16016 March 1999 Submits Current Limits of Property Insurance Maintained at Consumers Energy Co Operating Nuclear Power Plants ML18066A4131999-03-11011 March 1999 Responds to NRC 990210 Ltr Re Violations Noted in Insp Rept 50-255/98-22.Corrective Actions:Analytical Evaluation, EA-C-PAL-98-1067-01, P-50A Case to Cover Stud Evaluation, Was Submitted to NRC on 981220 ML18068A5241999-02-12012 February 1999 Resubmits Relief Request 12,with Addl Info That Includes Specific Locations Where Relief Request Would Be Applied,Per 10CFR50.55a(g)(5)(iii) ML18068A5211999-02-11011 February 1999 Informs NRC That Implementation of Formal Industry Position on Severe Accident Mgt at Palisades Plant Was Completed on 981217 ML18066A4051999-02-10010 February 1999 Requests Copy of Consumers Energy (Palisades) Formal Response to RAI Dtd 990512 (USI A-46) ML18066A3921999-01-29029 January 1999 Forwards Licensee Interpretation of TS Requirements for Performance of SRs as Applied to Instrumentation Channel Calibr.Ltr Established No New Commitments ML18066A3891999-01-28028 January 1999 Submits Response to Concern Expressed in Insp Rept 50-255/98-06 Re Whether Palisades ISI Program Was Being Conducted IAW Applicable Requirements 1999-09-30
[Table view] Category:UTILITY TO NRC
MONTHYEARML18057A4811990-09-17017 September 1990 Confirms 900718 Telcon Notification Re Westinghouse Agreement to Join Utils as Equity Investor in Plant ML18057A4551990-09-0606 September 1990 Forwards Proprietary Info Re Dept of Labor Decision on Discharge of Former Employee of Util,Per NRC 900809 Request. No 10CFR50.7 Violation Occurred Since Job Performance Was Reason for Discharge.Encl Withheld (Ref 10CFR2.790(a)(6)) ML18057A4521990-09-0404 September 1990 Submits Addl Info Re Circuit & Raceway Schedule Enhancement Project,Per Insp Rept 50-255/90-10.Electrical Cable Separation & Channelization Anomalies Identified During Review of Physical Raceway Installations Will Be Evaluated IR 05000255/19900101990-09-0404 September 1990 Submits Addl Info Re Circuit & Raceway Schedule Enhancement Project,Per Insp Rept 50-255/90-10.Electrical Cable Separation & Channelization Anomalies Identified During Review of Physical Raceway Installations Will Be Evaluated ML18057A4371990-08-31031 August 1990 Forwards Analysis Concluding That Plant Reactor Beltline Matl Upper Shelf Energy Will Remain Greater than 50ft-lbs Until Yr 2032,per 900716 Commitment ML18057A4381990-08-31031 August 1990 Forwards Info Re Contamination of South Radwaste Area,Per 10CFR20.302,in Response to NRC 900112 Request.Approval Requested to Dispose of Low Level Radwaste in Place ML20059E0001990-08-29029 August 1990 Forwards Semiannual fitness-for-duty Program Performance Rept for Jan-June 1990 ML18057A4201990-08-24024 August 1990 Forwards Revised Application for Amend to License DPR-20, Changing Tech Specs Re Incore Analysis Program.Request Revised Per NRC Comments During 900709 Meeting ML18057A4021990-08-22022 August 1990 Forwards Missing Pages from Decommissioning Funding Rept, Consisting of Pages 25 & 26 of Attachment a to Exhibit E ML18057A4241990-08-21021 August 1990 Forwards Application for Amend to License DPR-20,changing Tech Spec 4.5.1 Re Statement on Integrated Leak Rate Test ML18057A4071990-08-21021 August 1990 Forwards Tech Specs Change Request to License DPR-20,to Remove Redundant Requirements & Change Basis Statements No Longer Applicable ML18057A4121990-08-21021 August 1990 Forwards Application for Amend to License DPR-20,changing Tech Specs to Revise Wording for Reactor Protective Sys Trip Setting Limits for Steam Generator Low Water Level ML18057A4181990-08-21021 August 1990 Forwards Description of Changes Being Made to Plant Site Emergency Plan & Emergency Plan Changes.Change Allows Reduction in Shift Staffing During Cold Shutdown for Stated Staff ML18057A3911990-08-17017 August 1990 Forwards Replacement Pages,To Palisades Second 10-Yr Interval Inservice Insp Program. ML18057A3851990-08-17017 August 1990 Forwards Addl Info in Support of NRC Development of SER for full-term OL for Plant,Including Date of SER Providing Provisional OL to Plant & Summary of Valid Exemptions from 10CFR Regulations,Per Telcon ML18057A3841990-08-17017 August 1990 Provides Addl Info Re Transfer of Plant Ownership to Palisades Generating Co,Per NRC 900725 Ltr ML18057A3821990-08-14014 August 1990 Requests That Bechtel-KWU Rept 128901/MJS, Full Flow Testing of Motor-Operated Valve MO-1042A, Be Withheld (Ref 10CFR2.790(b)(1)) ML18057A3721990-08-0808 August 1990 Forwards Addl Info Re Util Request for Exemption from Separation Criteria of 10CFR50,App R,Section III.G.2 Re Containment Air Room ML20055J1421990-07-26026 July 1990 Responds to Commitment Oversight Issue Resulting from Insp Rept 50-255/90-08.Commitment Mgt Seminar Training Will Be Complete Prior to 901001 ML18057A3561990-07-26026 July 1990 Forwards Certification of Financial Assurance for Decommissioning ML18057A3411990-07-18018 July 1990 Forwards Revised Proposed Tech Spec Page 6-3,now Designated as Page 6-1b,adding Section 6.3.4,now Designated as Section 6.3.5 to Remove Organization Charts,Per Generic Ltr 88-06 ML18057A3381990-07-16016 July 1990 Advises That Util Does Not Foresee Need to Rely on Section V.C of App G to Remain in Compliance W/Upper Shelf Energy (Use) Requirements Re Use of Matl in Reactor Beltline ML18057A3281990-07-13013 July 1990 Responds to Request for Addl Info Re Second 10-yr Interval Insp Program,Per 900418 Telcon.Util 900329 Response Revised to Reflect That Certain Components in Class 2 Sys Should Not Be Exempted,Per IWC-1220 of 1974 ASME Code Section XI ML18057A3191990-07-0909 July 1990 Forwards Performance Indicator Trend Graphs for Jan 1989 - May 1990 ML18057A3201990-07-0606 July 1990 Discusses Reassessment of Control Room Temp Following Station Blackout Event.Results of Analysis Indicate That Control Room Temp Will Remain Below 112 F for 4 H After Onset of Blackout ML18057A3171990-07-0303 July 1990 Provides Summary of Upgrades Made to Plant Electrical Distribution Sys,Per 870714 Loss of Offsite Power Event When Inadvertent Actuation of Water Deluge Spray Sys for 1-2 Startup Transformer Resulted in Bus to Ground Fault ML20058K3771990-07-0202 July 1990 Forwards Rev 26 to Security Plan.Rev Withheld (Ref 10CFR73.21(c)) ML18057A3111990-06-25025 June 1990 Forwards Endorsements 116 & 117 to Nelia Policy NF-179 & Endorsements 102 & 103 to Maelu Policy MF-50 ML18057A3101990-06-25025 June 1990 Responds to Generic Ltr 90-04, Request for Info on Status of Licensee Implementation of Generic Safety Issues Resolved W/Imposition of Requirements on Corrective Actions. ML18057A3031990-06-22022 June 1990 Provides Addl Info Re Environ Qualification of Instrument Circuit Associated W/Steam Generator Pressure Channel PT-0752D,per Insp Rept 50-255/90-05.Circuits Spliced Directly to Pigtail from Electrical Penetration Connector ML18057A3001990-06-21021 June 1990 Concurs W/Nrc Change in Terminology & Submits Revised Proposed Section 4.14 of Tech Specs ML18057A2771990-06-15015 June 1990 Forwards Corrected NRC Form 474 Re Simulation Facility Certification,Indicating Exceptions to Ansi/Ans 3.5 ML18057A2901990-06-13013 June 1990 Forwards Application for Amend to License DPR-20,revising Tech Spec 3.3.1.b Re Safety Injection Tank Min Level ML18057A2941990-06-12012 June 1990 Advises That Submittal of Second Interval Inservice Insp Program Delayed from 900615 to 900715,per 900418 Telcon ML18057A2711990-06-11011 June 1990 Requests Temporary Waiver of Compliance from Tech Spec 3.1.1i in Order to Maintain Plant in Hot Shutdown While Repair Made to Pressurizer Heater Power Supply.Request Based on 900608 Failure of Heater Transformer 15 ML18057A2641990-06-11011 June 1990 Provides Response to NRC Requalification Exam Rept Dtd 900410 on NRC Concerns Re Facility & Training Ctr Staffing. Adequate Staffing Will Be Maintained to Ensure Operator Requalification Program Successful ML18057A2591990-06-11011 June 1990 Forwards Palisades Simulator Certification Submittal. ML18057A2631990-06-10010 June 1990 Requests Temporary Waiver of Compliance from Tech Spec 3.1.1i to Enable Plant to Be Maintained in Hot Shutdown While Repair Made to Pressurizer Heater Power Supply.Waiver Requested for 900611-18 ML18057A2571990-06-0808 June 1990 Responds to NRC 900509 Ltr Re Violations Noted in Insp Rept 50-255/90-12.Corrective Actions:Continuing Training Program Will Be Developed for Supervisors That Will Discuss Fire Protection Program Implementation Topics ML20043D0601990-06-0404 June 1990 Forwards Rev 25 to Security Plan,Including Changes to Security Plan Drawings to Clarify Protected Area Boundary within Plant Security Bldg & Vital Area Boundaries in Other Specific Vital Areas of Plant.Rev Withheld (Ref 10CFR73.21) ML18057A2581990-06-0101 June 1990 Forwards Revised Response to Violations Noted in Insp Rept 50-255/89-26.Concurs That Tests Performed Using Instrumented Insp Technique During 1988 Refueling Outage Considered Invalid ML18057A2561990-05-31031 May 1990 Advises That No NPDES Notifications Required Nor Any Repts of Oil or Salt Occurred During Nov 1989 - Apr 1990 ML18057A2541990-05-30030 May 1990 Forwards Response to Technical Evaluation Rept EGG-NTA-8333 Which Evaluated Plant Compliance w/NUREG-0737,Item II.D.1 & Requested Addl Info Re New PORVs & Block Valves No Later than Jan 1990 ML18057A2511990-05-30030 May 1990 Forwards Final Response to Concerns Re Porv/Block Valve Mod, Per 900308 Meeting.Bechtel Technical Rept Withheld ML18057A2501990-05-29029 May 1990 Forwards Investigation Rept Re Unsatisfactory Performance Testing of Fitness for Duty Program Blind Performance Test Samples ML18057A2411990-05-24024 May 1990 Forwards Revised Application to Amend License DPR-20, Consisting of Revised Attachments 1 & 5 to 890227 Amend Request,Reflecting Transfer of Plant Ownership ML18057A2311990-05-17017 May 1990 Forwards Analysis of Reactor Pressure Vessel Fast Neutron Fluence & PTS Ref Temps for Palisades Nuclear Plant. Rept Concludes That PTS Screening Criteria Will Be Exceeded at Axial Welds in Sept 2001 as Opposed to Mar 2002 ML18054B5861990-05-0707 May 1990 Forwards Monthly Trend Graph Rept for Jan 1989 - Mar 1990 Covering Safety Status Performance Indicators for HPSI, Auxiliary Feedwater,Emergency Ac Power,Lpsi,Containment Spray & Svc Water Sys ML18054B5801990-04-30030 April 1990 Responds to Request for Addl Info on Proposed Administrative Changes to Tech Spec Section 3.0.4,per Generic Ltr 87-09. Licensee Will Implement Program to Assure Appropriate Level of Mgt Approval Required When Operating Conditions Changed ML18054B5741990-04-25025 April 1990 Requests That Correspondence Re 890227 Application for Amend to License DPR-20 to Permit Transfer of Ownership of Plant Be Sent to Listed Address 1990-09-06
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i consumers Power company General Offices: 1945 West Parnell Road, *Jackson, Ml 49201 * {517) 1aa-osso October 28, 1985 Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
REQUEST FOR APPROVAL TO INSTALL ISOLATION SWITCHES -
COMPLIANCE WITH 10CFR50.48 AND APPENDIX R 10CFR50.48, Paragraph c.5 requires that design descriptions of modifications which affect alternate shutdown capability be submitted for prior review and approval. In the process of complying with that requirement, Consumers Power Company, in the June 19, 1985 fire protection submittal, committed to submit detailed drawings of the location of isolation switches installed in the control .circuits of essential safe shutdown equipment. The schematic drawings and design description contained in Attachment I furnish the necessary detail to perform a design review and are being submitted in lieu of detailed drawings. Attachment I provides the design description of switch installa-tions which may be necessary for the isolation of certain remote control circuits and thereby to ensure post-fire alternate shutdown capability.
Therefore, prior review and approval of these switches is required.
Furthermore, the installation of isolation switches in the control circuits of certain safety equipment has been determined to be an unresolved safety ques-tion as defined in Section a.2. of 10CFRS0.59 by the Palisades Plant Review Committee. Pursuant to 10CFR50.59 Section 2.c, Attachment I and II together provide a full description of the desired change and a safety analysis.
Engineering associated with these isolation switches has recently been com-pleted and installation is scheduled to begin as soon as NRC approval is received. Since the installation of these switches must be completed before plant startup from the upcoming refueling outage (startup is planned for mid
=-F-=e:.!:b~r-=u:.:a~ry_, 1986) your prompt attention to this matter is requested.
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- Director, Nuclear Reactor Regulation Palisades Plant Isolation Switches October 28, 1985 A check in the amount of $150.00 is enclosed as required by 10CFR170.21.
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James L Kuemin Staff Licensing Engineer CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades OC1085-0007B-NL02
ATTACHMENT I Consumers Power Company Palisades Plant Docket 50-255 ISOLATION SWITCHES DESIGN DESCRIPTION OF THE INSTALLATION OF ISOLATION SWITCHES TO COMPLY WITH THE CRITERIA OF 10CFR50.4S AND APPENDIX R October 28; 1985 FP1085-0007C-NL02
I-1 ATTACHMENT I Palisades Plant DESIGN DESCRIPTION OF THE INSTALLATION OF ISOLATION SWITCHES TO COMPLY WITH THE CRITERIA OF 10CFR50.48 AND APPENDIX R I. General Alternate safe shutdown capability depends on the transmission of electrical power from the 1-1 diesel generator to either a charging pump or a high pressure safety injection (HPSI) pump. In order to maintain an adequate margin of subcooling in the Primary Coolant System (PCS),
the 1-1 diesel must start within 2.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> of the time offsite power is lost. Worst case assumption is that offsite power is lost simultaneously with reactor trip.
In the Palisades electrical distribution system, when operating a 480V breaker, local control overrides a remote signal. Locally overriding a remote signal to the larger 2400 volt breakers is not as easily accomplished. Because of breaker design, the magnitude of the power involved, and personnel safety, the remote signal must be isolated from the breaker before local control is accomplished. For example, if a spurious trip signal from the remote circuit has caused the breaker to open, the only safe method of locally closing that breaker is to remove the trip signal by isolating it from the breaker.
A Cable Spreading Room fire, a Control Room fire, a f~re in the 590'
c*orr+/-dor-of-the-Auxi-1-ia*ry-Bu-i-ld-i-ng-or-an-Eng-ineer-ed-Saf.eguar.ds_Eanel________
Room fire, could cause an open or a hot short in the remote control FP1085-0007C-NL02
I-2 circuits of equipment which must be operable in order to operate the diesel generator, transmit electrical power from the diesel generator to the lC bus, transmit power from the lC bus to a service water pump which cools the diesel generator, and to transmit power from the lC bus to either a charging pump or a HPSI pump which, in turn, is necessary to maintain pressure, reactivity control, and inventory in the PCS. The service water pump and the HPSI pump receive their power directly from the lC bus. The charging pump can receive 480V power from a source in the Cable Spreading Room or a source in the Turbine Room. (See attached Sketch No 1.)
To ensure that malfunctions in control circuits will not cause the inoperability of the diesel generator or the breakers which must close to* transmit the required power, switches which will isolate the remote control circuits will be installed:
A. In the control circuit for volta~e control of diesel generator 1-1.
B. In the control circuit for speed control of diesel generator 1-1.
C. In the control circuit of breaker 152-107 which connects diesel generator 1-1 to the 2400 V lC bus.
D. In the control circuit of breaker 152-103 which conne.cts the lC bus to the service water pump P-7B.
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I-3 E. In the control circuit of breaker 152-110 which connects the IC bus to Station Power Transformer No. 13, located. in the Turbine Room, which can be used to supply 480 volt power to charging pumps P-55 B and C.
The isolation switches described in A and B above are to be located in the 1-1 Diesel Generator Room. The isolation switches described in C, D, and E will be located in the lC Switchgear Room.
In the case of a worst case fire in the 590' corridor of the Auxiliary Building renders the charging pumps P-55B and P-55C inoperable, HPSI pump P-66B will be used for PCS pressure, reactivity, and inventory control. Neither the control nor power circuits for P-66B are located in the 590' corridor fire area. Therefore, no isolation switch is required in the remote control circuit of HPSI pump P-66B.
II. Design Description A. Assumptions Basically, two types of "hot shorts" exist. One is the shorting of one wire to another wire. An example of this is illustrated in Figure 1. The other is the shorting of two wires in a circuit to two wires in another circuit and is ref erred to as a double "hot
shotct-.-"-~his-si.tua.tion-is-illustrated-in-Eigur.e_2_. _______________
FP1085-0007C-NL02
I-4 The first type of short, tbs single hot short, is protected against in the isolation circuit design. Isolation switches are located in control circuits such that they will remove the portion of the circuit which passes through the Cable Spreading Room, Control Room, 590' corridor, or Engineered Safeguards Panel Room. In addition, backup fuses are added to the local circuits to provide a redundant path of control power. The backup fuses are placed by the isolation switches, concurrent with remote circuit isolation, into the local control circuit. Therefore, not only will the isolation switches remove a portion of the faulted or potentially faulted circuit, they will also switch in redundant fuses and allow local operation of the equipment. This design is schematically presented in Figure 3.
The double "hot short" was not protected against in this design because it is not a credible occurrence. This decision was based on several cable design features. One cable carries the conductors (two or more) required for one circuit. The conductors are individually insulated and then are spirally bound within an outer jacket, thus the conductors are never in the same relative position with respect to the outer jacket.
In order to have a double "hot short," the spiralled conductors carrying the required voltage and polarity would have to contact
'each-o.the.r-in-exac.t-lo.cations_._This_co.n.tac.t_wo.uld_no_t_o.nly_haY-.e_t_o._______
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I-8 be one of exact-voltage and polarity, but it would also have to be the correct spiralled conductor in one cable with the correct spiralled conductor of another cable and neither conductor could contact the grounded cable tray or conduit.
Based on the low probability of the concurrent occurrence of these events, the double "hot short" is considered incredible. This position is similar to the established NRC position that a 3-phase motor need not be protected against a 3-phase short.
B. Design Description The installation of isolation switches results in modification of the control circuits for three breakers and Diesel Generator 1-1 and involves the installation of General Electric Type SBM Transfer Switches. The GE Type SBM switches have two positions, "local" and "remote." When the switches are in the "remote" position, the control circuits will operate as they presently exist - allowing operation from the control room. When the switches are switched to "local" then all control circuits outside the local equipment panels will be electrically isolated.
In all three breaker panels, backup control power fuses are added.
These fuses remain isolated from the control circuits until the
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control power will be available for the required breaker operation.
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I-9 The panels involved in this project are Breaker Panel 152-103 for power to Service Water Pump 7B, Breaker Panel 152-107 - the Diesel Generator 1-1 Output Breaker, Breaker 152-110 for power to Station Power Transformer # 13, Diesel Generator 1-1 exciter panel C22, and Diesel Generator 1-1 gauge panel G20.
Identical isolation switches are used in each of the five panels.
The switches have five contacts which are closed when the switch is in the "local" position and fifteen contacts which are closed when the switch is in the "remote" position. The number of contacts actually used to i.solate or enable the remote and local controls is different for each panel as illustrated in Table 1.
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I-10 TABLE 1 ISOLATION SWITCH CONTACT POSITION Contacts Contacts Used SEare Control Circuit Control Circuit Contact Switch Position Switch Position Panel No Position Local Remote Local Remote 152-103 Open 9 3 6 2 Closed 3 9 2 6 152-107 Open 8 2 7 3 Closed 2 8 3 7 152-110 Open 4 4 11 1 Closed 4 4 1 11 G-20 Open 14 2 1 3 Closed 2 14 3 1 C-22 Open 15 4 0 1 Closed 4 15 1 0 FP1085-0007C-NL02
1-11 As an added security measure, all five switches are equipped with unique removable handles. The handles are removed when the switch is in the "remote" position and the control circuits are operating normally. The switch handles are designed to only fit these control isolation switches and the isolation switches are designed to prevent handles from other switches being used to make them operate. The switches can be moved to the "local" position only when the proper handles are inserted. The handles can not be removed from the switch until the switch is placed back in the "remote" position. Access to these unique handles is to be administratively controlled.
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ATTACHMENT II Consumers Power Company Palisades Plant Docket 50-255 ISOLATION SWITCHES SAFETY ANALYSIS October 28, 1985 3 Pages FP1085-0007D-NL02
II-1 ATTACHMENT II SAFETY ANALYSIS Consumers Power Company presents this evaluation of the hazards considerations involved with the installation of isolation switches in the remote control circuits of equipment essential for hot shutdown as defined by 10CFR50.48 and Appendix R. The installation has been determined to be an unresolved safety question by the Plant Review Committee at Palisades.
The following analysis is pursuant to the requirements of 10CFR50.59, and 50.90; and will justify the.conclusion that the installation of isolation switches as described in Attachment I does not significantly increase the probability or consequences of an accident previously evaluated; create the possibility of a new or different kind of accident from an accident previously evaluated; or, involve a significant reduction in the margin of safety.
Therefore, a prompt approval to install the described isolation switches is justified.
inoperable. Failure of--ari-isolat-ion swHcn, except-dur*1n-g-H*s-p-o-stfire-opera--.--------
tion* after a worst case fire, can do nothing worse than make a piece of FP1085-0007D-NL02
II-2 redundant safe shutdown equipment inoperable. That is the same condition assumed during previously evaluated accident probabilities or consequences.
(Note that except for Loss of Offsite Power, the single failure criteria need not be applied to fire scenarios.)
The switches involved are qualified to IEE-344-1975 and are the same type used throughout industry. Installation and testing will meet the same codes and standards as used for other similarly classified equipment at Palisades.
Therefore, Consumers Power Company concludes that the installation of isola-tion switches as described in Attachment I does not significantly increase the probability or consequences of an accident previously evaluated.
The worst case failure of any or all of the switches installed, as described in Attachment I, can result in causing the 1-1 Diesel Generator, the lC 2400V bus, the P-7B Service Water Pump and the No. 13 Station Power Transformer to be inoperable. The inoperability of this equipment singularly or all at one time does not create the possibility of a new or different kind of accident, because redundant equipment is available. Therefore, no new or different kinds of accident from any accident previously evaluated is created.
Redundant equipment, whose function is not affected by the failure or opera-bility of the newly installed switches, is available to maintain the margin of safety associated with the effected systems. The probability of malfunction or failure of the new switches is small during the time that redundant equip-ment may be inoperable:--Tlie time fliat-tnis reoundant-e-quipment-ts-a-1.-lowed-to-------
be inoperable during plant operation is also restricted by the Technical FP1085-0007D-NL02
- II-3 Specifications. Switch design and the standards to which each is installed and tested result in a very reliable switching operation. Therefore, the amount of reduction in the margin of safety due to the* postulated failure of these switches is considered very small. The overall increase in the margin of safety due to the ability to quickly isolate remote controls after or during a worst case fire may have a more significant effect. The overall margin of safety, therefore, may have a net increase; or if it is reduced, is reduced by an insignificant amount.
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