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| | INTERIM REPORT' . |
| | Accession No. |
| | e |
| | . Contract Program er Project |
| | |
| | ==Title:== |
| | Fire Protection-in Operating Nuclear Power Stations: > |
| | Subject of this' Document: Palisades Safety Evaluation Report Review l 1 |
| | Type of Document: Letter. Report Author (s): R.E. Hall and E.A. MacDougall Date of Document: August 1978 . |
| | ~ |
| | Responsible NRC Individual Mr. Robert L. Ferguson and NRC Office or Division: Division of Operating Reactors , |
| | Office of Nuclear Reactor Reg. |
| | U.S. Nuclear Regulatory Commission Washington, D.C. 20555 This document was prepared primarily for preliminary or internal use. It has not received full review and approval. Since there > |
| | may be substantive changes, this document should not be considered final. |
| | b Brookhaven National Laboratory Upton, NY 11973 Associated Universities, Inc. |
| | I for the U.S. Department of Energy Prepared for ! |
| | U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Under Interagency Agreement EY-76-C-02-0016 NRC FIN No. A-3107 INTERIM REPORT t |
| | l |
| | |
| | . o Y kmI 60g BROOKHAVEN NATIONAL LABORATORY , l 7E[9 |
| | % ua = |
| | ASSOCIATED UNIVERSITIES, INC. |
| | Upton, New York 11973 Department of Nuclear Energy (516) 345-2144 August 30, 1978 Division of Operating Reactors U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Mr. Robert, L. Ferguson Plant Systems Branch |
| | |
| | ==Dear Bob:== |
| | |
| | ==SUBJECT:== |
| | Fire Protection in Operating Nuclear Power Stations - Palisades Safety Evaluation Report Review The Safety Evaluation Report, dated July 21, 1978, as developed jointly by the NRC staff and Brookhaven National Laboratory (BNL), adequately reflects the concerns and recommendations of the consultants. Throughout the r.eeval-uation'of Palisades, there has been general agreement between the NRC staff and the BNL consultants. Based on present data, the proposed fire protection, as set forth in the SER, will give reasonable assurance that the health and ' |
| | l safety of the public is not endangered. The following exception represents a differing engineering point of view that should be evaluated by the NRC staff. |
| | : 1. Turbine Building SER Item 5-15 concludes that fire protection in the turbine building is acceptable. However, the licensee's fire hazard analysis does not adequately address the consequences of an unsuppressed lube oil ! |
| | fire in the turbine building (see {{letter dated|date=October 24, 1977|text=October 24, 1977 letter}} from l L.P. Herman to R.E. Hall on this subject.) |
| | : 2. Control Valves SER Item 4.3.1.3 indicates that the position of fire protection system valves will be controlled by locks or seals with periodic ; |
| | inspections. Locking or sealing programs depend upon ongoing administrative controls that are subject to human failure. Locks , |
| | can also prevent prompt water shutoff if piping ruptures. It is i valves for fire protection systems protecting areas containing or exposing safeh'-related equipment. |
| | 11C ,lesearci anc' Teclnical Assistance Report |
| | 'rs u n o 213 |
| | : 3. Seismic Damage The SER does not consider the effect of seismic damage on primary and back-up fire protection systems, although Branch Technical Position 9.5-1 addresses this item for new plants. It is recommended that the potential that a seismic event could cause both a fire and damage to the protective features provided to cope with the fire be further evaluated. This should include fires started in nonseismi-cally qualified systems or areas that spread to safety-related sys-tems because protective systems are damaged. |
| | : 4. Smoke Removal SER Item 4.4.1 indicates that portable fans and ducts will be accepted as a means for removing smoke from many plant areas. Fires in elec-trical insulation can generate copious amounts of dense smoke which hamper fire control efforts by rendering the atmosphere toxic and reducing visibility in the area. Properly used, self-contained breathing apparatus can minimize the problem of toxic atmosphere, but little can be done to improve visibility except to remove the smoke from the building. |
| | Massive changed will be required in most areas of this plant if effective permanent smoke removal systems are required, the design of which would also have to include consideration of radioactivity releases. While portable fans and ducts may be effective for smoke control in may instances, there is concern that they will not be sufficient for a major fire in some areas of the plant. It is recommended that this item be held open until better guidelines are developed for the evaluation of smoke generation potential and smoke removal system design. |
| | / |
| | : 5. Protective Signaling System i Portions of the protective si )naling system utilize unsupervised d wiring. NRC has required an increased frequency of testing for this system. It is reconmended that supervised circuits be re-quired instead. |
| | : 6. Yard Hydrant Eouipment - Section 3.1.2 This section as written appears' too " general" and brief, in that it does not require certain essential tools and equipment; i.e. |
| | hydrant wrenches, hose spanner wrenches, spare hose gaskets. See JHR Report par. 8.0, page 15; and Sec. 5-6.1 NFPA No. 24 - 1977. |
| | : 7. Non-Safety Related Hydrants It is recommended that hydrant no. 6 be barricaded against possible vehicle damage. |
| | l |
| | |
| | The. preceding. statements-are based on a detailed reevaluation of the Lfire protection program as implemented by the Consumers Power Company at the Palisades Nuclear Power Station. The-analysis covered a review of the fire prevention, detection and_ suppression capabilities of the Palisades unit as interfaced.with the nuclear systems requirements. This was accomplished by utilizing a review team concept with members from BNL and the Nuclear Reg-ulatory Commission Division of Operating Reactors staff. |
| | The fire protection evaluation .for Palisades is based on an analysis of documents submitted by the Consumers Power Company to the Nuclear Regulatory Commission and a site visit. The site visit was conducted by Mr. J.E. Knight and Mr. H.J. George of the NRC; Mr. L. Paul Herman of Rolf Jensen and Asso-ciates, Inc. , under contract to BNL; and Mr. J. Riopelle was under contract' to BNL to review the manual-fire fighting capabilities of the station along with administrative controls. |
| | The Palisades review has been conducted under the direction of Mr. E. MacDougall and myself of the Reactor Engineering Analysis Group at BNL, and has had the following major milestone dates. |
| | : 1. The CPC " Fire Protection Program Evaluation" was transmitted to NRC on March 31,-1977. |
| | : 2. On September 29,-1977, CPC transmitted a supplement to their original evaluation for the reactor containment building. |
| | : 3. On January 30, 1978, NRC transniitted a Staff Position and Requests for Additional Information based on an initial review of the CPC submi ttals. , |
| | : 4. The site visit was conducted on May 8-12, 1978. The ' primary Review Team consisted of James E. Knight and Henry J. George of the NRC staff, James H. Riopelle, private consultant, and L. Paul Herman of Rolf Jensen- and Associates, Inc. Mr. Knight served as 4 team leader and spokesman. $ |
| | : 5. On May 15, 1978, CPC transmitited responses to the initial NRC Pas-ition and Requests for Additional Information |
| | : 6. On May 24, 1978, NRC transmitted further staff Positions and Requests for Additional Information based on the site visit. |
| | : 7. On June 30, 1978, CPC transmitted responses to the site visit Pos - |
| | itions and Requests for Additional Information. |
| | : 8. The SER draft' associated with this report is attached to a memo. |
| | from G.C. Lainas to D. Ziemann, dated July 21, 1978. |
| | : 9. Certain modifications to the SER draft identifiad above were con-tained in a mema from Hank George to Dick Silver dated August 2, 1978. |
| | |
| | -4 i |
| | This. review process has resulted in identifying areas of the plant in |
| | - which a-fire could have undesirable' effects. on safe shutdown of the reactor and on release of- radioactivity to the environment. . The Utility's proposed modifications are'significant steps in reducing the undesirable effects of , |
| | -i a fire in this plant. |
| | . Respectfully yours, , |
| | // fc r |
| | [Mh obert E.. Hall,. Group Leader |
| | - Reactor Enqineering Analysis ; |
| | EAM:sd |
| | { |
| | 7 i |
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| | |
| | DISTRIBUTION M. Antonetti 1 |
| | : 1. Asp 1 V. Benaroya 1 E. Blackwood I W. Butler 1 R. Cerbone 1 D. Eisenhut 1 R. Feit 1 R. Ferguson 5 R. Hall 1 S. Hanauer 1 |
| | . P'. Herman 1 |
| | . E. Imbro 1 W. Kato 1 J. Klevan I G. Lainas 1 C. Long 1 E. MacDougall 1 J. Riopelle 1 V. Stello 1 T. Telford 1 H. Todosow 2 J. Townley 1 PDR- 2 |
| | _ _}} |
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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:RESEARCH AND TECHNICAL ASSISTANCE REPORTS
MONTHYEARML20072J2761983-02-28028 February 1983 Ser,Pump & Valve Inservice Testing Program,Palisades Nuclear Plant, Interim Rept ML20027D2221982-07-31031 July 1982 Redundant DHR Capability,Palisades Nuclear Power Plant. ML20052H5021982-04-30030 April 1982 Redundant Decay Heat Removal Capability,Palisades Nuclear Power Plant, Preliminary Rept ML20039A6821981-11-30030 November 1981 SEP Topic V-11.A,Electrical,Instrumentation,& Control Features for Isolation of High & Low Pressure Sys,Palisades Nuclear Station, Informal Rept ML20039A4521981-11-30030 November 1981 Adequacy of Station Electric Distribution Sys Voltages, Palisades Plant, Informal Rept ML20008F7891981-04-30030 April 1981 Adequacy of Station Electric Distribution Sys Voltages, Palisades Plant, Informal Rept for Apr 1981 ML19341B3841980-12-31031 December 1980 Technical Evaluation Rept,Degraded Grid Protection for Class IE Power Sys,Palisades Plant. ML20204D1621978-08-30030 August 1978 Interim Rept on SER Review Re Fire Protection Program. Inadequately Covered Items:Lube Oil Fire in Turbine Bldg, Control Valves Subj to Human Failure,Effect of Seismic Damage,Smoke Removal by Ducts & Wiring in Signaling Sys 1983-02-28
[Table view] Category:RESEARCH INSTITUTION/LABORATORY TO NRC
MONTHYEARML18054B5641989-04-18018 April 1989 Summarizes 890413 Meeting W/Util & Consultants in Jackson,Mi Re Review of Eddy Current Qualification Program ML20214E1721986-02-25025 February 1986 Ack Receipt of 860210 & 21 Ltrs Accepting Task Orders 3 & 4 Under FIN A-3552 & Task Order 5,respectively.Orders Include Work at Palisades & LaSalle Stations & Mod Review at Davis-Besse.Modified Task Order 4 Under FIN A-3550 Encl ML18047A3301982-04-28028 April 1982 Comments on SEP Integrated Plant Safety Assessment,Per Request.Sep Program Appears Well Organized ML18047A3271982-04-27027 April 1982 Submits Technical Evaluation Rept on Facility Integrated Plant Safety Assessment Per Draft NUREG-0820.Rept Fulfills Intent of SEP ML18047A3401982-04-16016 April 1982 Forwards Draft Review of SEP Rept.Mods Could Be Discussed During 820419 Trip to Bethesda,Md & Implemented by 820529 Deadline.Critique of Contents Could Be Beneficial When Ginna Rept Available ML18047A4231982-03-24024 March 1982 Notifies That Control Room Meets Requirements of SRP 2.2.1 - 2.2.2,2.2.3 & 6.4 & General Design Criteria 4 & 19. Conclusions Based on Present Plant Sys & Presumes Implementation of Effective HVAC Mods by Licensee ML18046B1151981-11-24024 November 1981 Forwards Summary of Review of Open Equipment Items for Palisades Nuclear Power Station. Info Result of 811106 Meeting W/Util ML18046B1761981-11-20020 November 1981 Suppls Draft 811006 Ltr,Developing Basis for Recommendations for Changes to Sssp Spectrum to Account for Soil Column ML19351A1191981-05-0101 May 1981 Forwards marked-up Draft SEP Containment Analysis & Evaluation for Facility ML18046A7461981-02-17017 February 1981 Provides Status on SEP Containment Analysis for Facility. Containment Design Temp Is Exceeded in Some Cases.W/O Stated Encls ML19345D6991980-11-24024 November 1980 Submits Monthly Mgt Ltr 8 for Oct 1980 Re Containment Analysis Support for Sep. ML19344B1261980-07-31031 July 1980 Forwards Review of Facility Containment Integrity Analysis for SEP Containment Analysis Support,To Satisfy Requirements of Subtasks 1,2 & 5.Requests Review of Rept ML20204D1621978-08-30030 August 1978 Interim Rept on SER Review Re Fire Protection Program. Inadequately Covered Items:Lube Oil Fire in Turbine Bldg, Control Valves Subj to Human Failure,Effect of Seismic Damage,Smoke Removal by Ducts & Wiring in Signaling Sys 1989-04-18
[Table view] |
Text
. __ _ _ . . . _
INTERIM REPORT' .
Accession No.
e
. Contract Program er Project
Title:
Fire Protection-in Operating Nuclear Power Stations: >
Subject of this' Document: Palisades Safety Evaluation Report Review l 1
Type of Document: Letter. Report Author (s): R.E. Hall and E.A. MacDougall Date of Document: August 1978 .
~
Responsible NRC Individual Mr. Robert L. Ferguson and NRC Office or Division: Division of Operating Reactors ,
Office of Nuclear Reactor Reg.
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 This document was prepared primarily for preliminary or internal use. It has not received full review and approval. Since there >
may be substantive changes, this document should not be considered final.
b Brookhaven National Laboratory Upton, NY 11973 Associated Universities, Inc.
I for the U.S. Department of Energy Prepared for !
U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Under Interagency Agreement EY-76-C-02-0016 NRC FIN No. A-3107 INTERIM REPORT t
l
. o Y kmI 60g BROOKHAVEN NATIONAL LABORATORY , l 7E[9
% ua =
ASSOCIATED UNIVERSITIES, INC.
Upton, New York 11973 Department of Nuclear Energy (516) 345-2144 August 30, 1978 Division of Operating Reactors U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Mr. Robert, L. Ferguson Plant Systems Branch
Dear Bob:
SUBJECT:
Fire Protection in Operating Nuclear Power Stations - Palisades Safety Evaluation Report Review The Safety Evaluation Report, dated July 21, 1978, as developed jointly by the NRC staff and Brookhaven National Laboratory (BNL), adequately reflects the concerns and recommendations of the consultants. Throughout the r.eeval-uation'of Palisades, there has been general agreement between the NRC staff and the BNL consultants. Based on present data, the proposed fire protection, as set forth in the SER, will give reasonable assurance that the health and '
l safety of the public is not endangered. The following exception represents a differing engineering point of view that should be evaluated by the NRC staff.
- 1. Turbine Building SER Item 5-15 concludes that fire protection in the turbine building is acceptable. However, the licensee's fire hazard analysis does not adequately address the consequences of an unsuppressed lube oil !
fire in the turbine building (see October 24, 1977 letter from l L.P. Herman to R.E. Hall on this subject.)
- 2. Control Valves SER Item 4.3.1.3 indicates that the position of fire protection system valves will be controlled by locks or seals with periodic ;
inspections. Locking or sealing programs depend upon ongoing administrative controls that are subject to human failure. Locks ,
can also prevent prompt water shutoff if piping ruptures. It is i valves for fire protection systems protecting areas containing or exposing safeh'-related equipment.
11C ,lesearci anc' Teclnical Assistance Report
'rs u n o 213
- 3. Seismic Damage The SER does not consider the effect of seismic damage on primary and back-up fire protection systems, although Branch Technical Position 9.5-1 addresses this item for new plants. It is recommended that the potential that a seismic event could cause both a fire and damage to the protective features provided to cope with the fire be further evaluated. This should include fires started in nonseismi-cally qualified systems or areas that spread to safety-related sys-tems because protective systems are damaged.
- 4. Smoke Removal SER Item 4.4.1 indicates that portable fans and ducts will be accepted as a means for removing smoke from many plant areas. Fires in elec-trical insulation can generate copious amounts of dense smoke which hamper fire control efforts by rendering the atmosphere toxic and reducing visibility in the area. Properly used, self-contained breathing apparatus can minimize the problem of toxic atmosphere, but little can be done to improve visibility except to remove the smoke from the building.
Massive changed will be required in most areas of this plant if effective permanent smoke removal systems are required, the design of which would also have to include consideration of radioactivity releases. While portable fans and ducts may be effective for smoke control in may instances, there is concern that they will not be sufficient for a major fire in some areas of the plant. It is recommended that this item be held open until better guidelines are developed for the evaluation of smoke generation potential and smoke removal system design.
/
- 5. Protective Signaling System i Portions of the protective si )naling system utilize unsupervised d wiring. NRC has required an increased frequency of testing for this system. It is reconmended that supervised circuits be re-quired instead.
- 6. Yard Hydrant Eouipment - Section 3.1.2 This section as written appears' too " general" and brief, in that it does not require certain essential tools and equipment; i.e.
hydrant wrenches, hose spanner wrenches, spare hose gaskets. See JHR Report par. 8.0, page 15; and Sec. 5-6.1 NFPA No. 24 - 1977.
- 7. Non-Safety Related Hydrants It is recommended that hydrant no. 6 be barricaded against possible vehicle damage.
l
The. preceding. statements-are based on a detailed reevaluation of the Lfire protection program as implemented by the Consumers Power Company at the Palisades Nuclear Power Station. The-analysis covered a review of the fire prevention, detection and_ suppression capabilities of the Palisades unit as interfaced.with the nuclear systems requirements. This was accomplished by utilizing a review team concept with members from BNL and the Nuclear Reg-ulatory Commission Division of Operating Reactors staff.
The fire protection evaluation .for Palisades is based on an analysis of documents submitted by the Consumers Power Company to the Nuclear Regulatory Commission and a site visit. The site visit was conducted by Mr. J.E. Knight and Mr. H.J. George of the NRC; Mr. L. Paul Herman of Rolf Jensen and Asso-ciates, Inc. , under contract to BNL; and Mr. J. Riopelle was under contract' to BNL to review the manual-fire fighting capabilities of the station along with administrative controls.
The Palisades review has been conducted under the direction of Mr. E. MacDougall and myself of the Reactor Engineering Analysis Group at BNL, and has had the following major milestone dates.
- 1. The CPC " Fire Protection Program Evaluation" was transmitted to NRC on March 31,-1977.
- 2. On September 29,-1977, CPC transmitted a supplement to their original evaluation for the reactor containment building.
- 3. On January 30, 1978, NRC transniitted a Staff Position and Requests for Additional Information based on an initial review of the CPC submi ttals. ,
- 4. The site visit was conducted on May 8-12, 1978. The ' primary Review Team consisted of James E. Knight and Henry J. George of the NRC staff, James H. Riopelle, private consultant, and L. Paul Herman of Rolf Jensen- and Associates, Inc. Mr. Knight served as 4 team leader and spokesman. $
- 5. On May 15, 1978, CPC transmitited responses to the initial NRC Pas-ition and Requests for Additional Information
- 6. On May 24, 1978, NRC transmitted further staff Positions and Requests for Additional Information based on the site visit.
- 7. On June 30, 1978, CPC transmitted responses to the site visit Pos -
itions and Requests for Additional Information.
- 8. The SER draft' associated with this report is attached to a memo.
from G.C. Lainas to D. Ziemann, dated July 21, 1978.
- 9. Certain modifications to the SER draft identifiad above were con-tained in a mema from Hank George to Dick Silver dated August 2, 1978.
-4 i
This. review process has resulted in identifying areas of the plant in
- which a-fire could have undesirable' effects. on safe shutdown of the reactor and on release of- radioactivity to the environment. . The Utility's proposed modifications are'significant steps in reducing the undesirable effects of ,
-i a fire in this plant.
. Respectfully yours, ,
// fc r
[Mh obert E.. Hall,. Group Leader
- Reactor Enqineering Analysis ;
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DISTRIBUTION M. Antonetti 1
- 1. Asp 1 V. Benaroya 1 E. Blackwood I W. Butler 1 R. Cerbone 1 D. Eisenhut 1 R. Feit 1 R. Ferguson 5 R. Hall 1 S. Hanauer 1
. P'. Herman 1
. E. Imbro 1 W. Kato 1 J. Klevan I G. Lainas 1 C. Long 1 E. MacDougall 1 J. Riopelle 1 V. Stello 1 T. Telford 1 H. Todosow 2 J. Townley 1 PDR- 2
_ _