ML20207J288

Responds to Noncompliances Noted in Insp Rept 50-155/85-22. Corrective Actions:Exemption from 10CFR50,App R,Section III.G.2 Requested & New Batteries for 8 H Emergency Lights Installed.Corrections to & Comments on Rept Encl

ML20207J288
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	09/02/1986
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8701080375
Download: ML20207J288 (8)

Text

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b a ikensing namnenus enaeuss General Offees: 1945 West Parnall Road. Jackson, MI 49201 . (517) 788 1636 September 2, 1986 James G Keppler, Administrator Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

RESPONSE TO INSPECTION REPORT 50-155/85022 - FIRE PROTECTION Three items of noncompliance were identified in Inspection Report 50-155/85022. One of the noncompliance items, identified as Item 3 in the Notice of Violation enclosed with the inspection report cover letter, con-cerned the storage of combustibles. With reapect to Item 3, the cover letter stated that the inspection showed that action had been taken to correct and prevent recurrence of that noncompliance and that the NRC had no further questions regarding Item 3 at this time.

This letter provides Consumers Power Company's response to the two noncompli-ances identified as Item 1 and Item 2 in the Notice of Violation enclosed with

! the Inspection Report. Attachment I provides a number of corrections and comments generated during our review of the subject Inspection Report.

ITEM 1 (NONCOMPLIANCE 155/85022-03) 10 CFR 50.48(b) in part requires that all nuclear power plants licensed to operate prior to January 1, 1979, shall satisfy the applicable requirements of Appendix R to this part, including, specifically, the requirements of Section III.G, Fire Protection of Safe Shutdown Capability.

Contrary to the above, the licensee failed to request an exemption from the requirements of Section III.G.2 of Appendix R after determining that the fire protection features in the Screenwell and Pump House did not meet the specific

, requirements of Section III.G.2 in that no fire suppression system was in-stclied in this area. In addition, no alternate shutdown capability was l

l provided for the Screenwell and Pump House.

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9 Admi'nistrator, Region III 2 Big Rock Point Plant Response to IEIR 85-022 - Fire Protection September 2, 1986 Corrective Actions Taken and the Results Achieved As discussed in the July 18, 1986 meeting with the NRC at the Plant site, an exemption request to 10 CFR 50 Appendix R.Section III.G.2 was submitted to the NRC by letter dated July 1, 1986. Until such time as this item is re-solved, compensatory measures in the form of periodic surveillances have been implemented. This compencatory measure was described in our letters dated April 14, 1986 and April 23, 1986.

Corrective Actions to be Taken to Avoid Further Violations Compensatory action in the form of periodic surveillances will be continued until this item is resolved.

Date When Full Compliance Will Be Achieved Full compliance will be achieved when this iten is resolved with the NRC.

Until that time, adequate compensatory measures are being taken.

ITEM 2 (NONCOMPLIANCE 155/85022-04) 10 CFR 50, Appendix B, Criterion XVI requires corrective action measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, defective material and equipment, deviations, and nonconformances are promptly identified and corrected. In the case of signif-icant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.

Consumers Power Company Quality Assurance Program for operational Nuclear Power Plants, Section 5.9 states, " Conditions adverse to fire protection, such as test failures, malfunctions, defective components and uncontrolled combus-tible material and fire incidents, are documented and corrective actions are accomplished according to QAPP 17-51."

Contrary to the above, the licensee identified that a problem existed with the eight hour emergency lighting system on August 16, 1984, however, the lighting system deficiencies still existed on May 8, 1986.

Corrective Actions Taken and Results Achieved As discussed in our April 14, 1986 letter to NRC and modified by our August 12, 1986 letter, a modification is in progress which will increase the capacity of the emergency lighting units. The modification involves adding an additional battery unit at each location and removing one of the existing two lamps and connecting it to the new battery. Each battery will power only one 12-watt lamp instead of the previous two, thereby effectively doubling the time rating on each unit to insure the required eight hour operability.

As of the date of this letter, all the new batteries have been installed and the lighting units are operational.

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. ' Admihistrator, Region III 3 Big Rock Point Plant Response to IEIR 85-022 - Fire Protection 1 September 2, 1986 Corrective Actions to be Taken to Avoid Further Violations The installation of two batteries per 2-bulb inside lighting unit and yearly 8-hour testing of each unit will prevent recurrence. The delay experienced in determining proper corrective action is considered abnormal and was the result of a design deficiency which required the consideration, installation, and testing of other proposed modifications. Therefore, we consider this to be an isolated incident.

Date When Full Compliance Will Be Achieved Full compliance for the inside emergency lighting units has been achieved as of the date of this letter.

Clarification ,

1 The Notice of Violation and the Inspection Report refer to Section 5.9 of Consumers Power Company Quality Assurance Program for Operational Nuclear Power Plants, and then further reference QAPP 17-51. These references are outdated. The correct current references are the Big Rock Point Fire Protec-tion Program Report,Section IV.C.8 and the Consumers Power Company Quality Assurance Program Description for Operational Nuclear Power Plants, CPC-2A, Section 16.

I l Kenneth W Berry Director, Nuclear Licensing i CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector - Big Rock Point Attachment 1

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9 ATTACHMENT I Consumers Power Company Big Rock Point Plant Docket 50-155 CLARIFYING COMMENTS AND CORRECTIONS DURING REVIEW OF INSPECTION REPORT 50-155/85022 September 2, 1986 O

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ATTACHMENT I During our review of the inspection report, a number of corrections and clarifying comments were generated. This information is provided in order to ensure an accurate understanding of fire protection measures at the Big Rock Point Plant.

(1) Page 9 Section 3.a

.The list of systems required for shutdown includes:

- Demineralized Water Tank (pump cannot be connected to EDG)"

COMMENT: It should be clarified that for the cases where the demineralized water system is used for emergency condenser shell makeup, the demineralized water pump can be connected to the emergency diesel generator (EDG) through the manual alignment of breakers in the electrical equipment room. In the case of a screenhouse fire, the standby diesel generator can be connected to the demineralized water pump in the same fashion using a different breaker alignment. These actions are covered by existing procedures dealing with loss of offsite power.

(2) Page 10, Section 3.a(1)

The report states that " Loss of offsite power also causes the reactor to trip. In the event that offsite power is not lost, the reactor can be tripped by throwing the breakers for the control rod drive pumps".

CORRECTION: Loss of station power, not necessarily offsite power, causes the reactor to trip. Opening the breakers supplying the reactor protection system will scram the reactor. Opening the CRD pump breakers would not cauee a scram.

(3) Page 10, Section 3.a(2)

In the description of inventory control, if the control rod drive pumps are unavailable, low pressure makeup is provided by the fire system through the core spray valves. The report states "the plant would remain in hot shutdown in this case".

COMMENT: The plant would remain in hot shutdown if both of the reactor cooling water pumps were also unavailable due to the fire.

(The cables for the CRD pumps run within 20 feet of the RCW pumps.) If a reactor cooling water pump remains available, such as for a fire in the control rod drive pump room, the plant would proceed to cold shutdown.

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2 (4) Page 11, Section 3.a(3)

The report states "the water on the shell side of the EC is allowed to boil off and is discharged into atmosphere through a high stack".

4 Minor Correction: The emergency condenser vents at the top of the containment sphere, not through the plant stack.

(5) Page 12, Section 3.a(3)

The fourth paragraph on this page states that the remotely operated solenoid valve for EC makeup was not identified in the March 8, 1983 SER.

CORRECTION: Page 5 of Enclosure 2 of the March 8, 1983 SER identifies the fact that the " auxiliary shutdown control station will contain controls for the ... valves for firewater make-up to the emergency condenser".

(6) Page 13, Section 3.a(5)

This section deals with support systems to maintain hot shutdown, "re-quired for either method of shutdown, ie, use of the EC or use of the RDS/ core spray systems, except as noted:

(a) Domineralized water system including air compressor and air-operated

demineralizer flow isolation valve (for EC method only)."

COMMENT: Note that this system is used for EC makeup whenever it is available. If it is not available, the firewater system is used through the firewater makeup solenoid valve.

Note also that EC makeup is used to achieve cold shutdown rather than maintain hot shutdown in almost all cases, as it

! lowers the primary system pressure to the point where the shutdown cooling system is put into service. EC makeup is l

used to maintain hot shutdown only in cases where normal cold I

shutdown pumps are lost due to the fire and hot shutdown is l maintained rather than use ' feed and bleed' to achieve cold i shutdown (eg, loss of both shutdown cooling pumps), or in cases where cold shutdown could be achieved but hot shutdown is maintained only for convenience.

(b) " Firewater system including core spray valves and flow paths (RDS method only)".

COMMENT: This system can also be used for low pressure primary system makeup in the EC method by opening the core spray valves manually.

(c) " Control rod drive pumps and condensate storage tank".

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3 COMMENT: This system is never used in conjunction with the RDS/ core spray method of shutdown, only for the EC method.

(d) "AC power from the EDG" COMMENT: For hot shutdown, for the EC method, the EDG is used only for powering the control rod drive pump.

(e) "AC power from the SDG (see Section 4.2.2)"

COMMENT: There is no nection 4.2.2. Apparently refers to Section 3.b.2.

(7) Page.14, Section 3.a(6)

The report states that "each fire pump is capable of 1200 gym at 115 psia".

COMMENT: Each fire pump is rated at 1000 gpm at 110 psig. Note that the intent of the analyses referred to on this page was merely to show that the flow rate necessary to remove decay heat after two or three days is very small, less than 50 gpm.

(8) Page 15. Section 3.a(6)

The report advises against using the CRD pumps in place of the fire pumps for feed and bleed, becaase of the high discharge pressure capability of the purps. It states that " based on the above, operating procedures for

, feed and bleed, procedures should be written and implemented accordingly".

COMMENT: The only procedures in place that would be associated with a feed and bleed method of operation are the existing proce-dures dealing with the RDS and core spray stems. No mention is made of using a CRD pump. In addition, existing technical.

specifications contain the restrictions on acceptable cool-down limitations.

(9) Page 19, Section 3.b(2) j

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The report states that " diesel-driven fire pump was proposed to be used to provide makeup to the EC shall side and also to the FCS by means of the DC powered core spray valves in conjunction with the DC powered RDS".

CORRECTION: It is true that in this case (loss of the EDG) the DC core spray valves would be used with the fire pump for PCS makeup, but not in conjunction with RDS. RDS is not used ic this 4 scenario.

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4 (10) Page 24, Section 5.b(3)

The table lists M07062 as disabled c.losed.

CORRECTION: The resolution for M07062 should be the same as for M07052, ie, reroute cable for coil actuation. It is not disabled closed.

(11) Page 28, Section 7.b(2)

The first sentence states "..... a postulated fire in the Emergency Diesel Generator Rcom that involves both redundant fire water pumps, the use of .....".

CORRECTION: The sentence should read .... a postulated fire in the Emergency Diesel Generator Room or in the Screenhouse, the use of .... (The screenhouse contains portions of the EDG feeder cable.)

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