ML18043A901
| ML18043A901 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/05/1979 |
| From: | Dewitt R, Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 7908030597 | |
| Download: ML18043A901 (7) | |
Text
consumers Power company General Offices: 212 West Michigan Avenue, Jackson, Michigan 49201
- Area Code 517 788-0550 June 5, 1979 Mr James G Keppler Office of Inspection and Enforcement Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - ADDITIONAL ACTIONS REQUESTED OF THE LICENSEE REGARDING IE BULLETIN 79-06B Consumers Power Company's response to the additional questions telecopied from NRC (Washington, DC) on May 22, 1979 is as follows (the item numbers correspond to the bulletin's action item):
Item 1. c Provide assurance that all licensed operators and plant management and supervisors with operational responsibilities have participated in the review requested by item 1 of the bulletin.
Response
All Licensed Operators and Plant Management and Supervisors with operational
- responsibilities have participated in the review requested by Item 1 of the bulletin.
Item 2.a Provide assurance that appropriate procedural guidance is available to the operator for monitoring the core for possible voiding during the natural circulation mode.
In addition, identify the availability and use of all 0 7 1979 oc0679-0048a-46
2 instrumentation to monitor core conditions under forced or natural circulation modes of operation.
Response
Emergency Procedure D-4.34 provides appropriate guidance to the operator for monitoring the core for possible voiding during the natural circulation mode.
This procedure calls for the use of the following instruments which are all located in the control room and used routinely:
- 1.
Pressurizer Level
- 2.
TH
- 3. Tc
- 4.
Reactor Pressure
- 5.
Steam Generator M> - Flow
- 6.
Primary Coolant Pump Vibration 7.
Primary Coolant Pump Current Item 3 For any lines not isolated upon automatic initiation of safety injection provide justfication that the line is needed to prevent degradation of needed safety features or cooling capability. It is our position, stated in the bulletin, that unless a line is needed for safety features or cooling capability, it should be isolated upon initiation of safety injection.
Provide assurance that you have completed the evaluation of the potentially deleterious effects of interrupting PCP seal bleed-off and have implemented corrective measures, if needed to eliminate the deleterious effects and to assure not isolating bleed-off would not degrade containment.
Response
Consumers Power Company received.a clarification and expansion of Item 3 from the NRC by telecopy at 10:50 AM on May 23, 1979.
Our response to the expanded question is as follows:
(a)
For all lines penetrating containment that are automatically isolated in the event of an accident, identify the parameters sensed that will oc0679-0048a-46
- . -Jo initiate automatic containment isolation.
Also, indicate the AND and OR logic associated with these parameters.
Response
3 The containment penetrations which receive automatic isolation signals are identified in Attachment 1. provides definitions of the containment penetrations classes which are identified in the first column of Attachment 1.
The parameters which initiate containment isolation and the logic associated with each are as follows:
Containment Isolatio.n Containment High Pressure:
Containment High Radiation:
Safety Injection Containment High Pressure:
Pressurizer Low Pressure:
Main Steam Line Isolation 2/4 Logic 2/4 Logic 2/4 Logic 2/4 Logic Steam Generator Low Pressure:
2/4 Logic (b)
For lines penetrating the containment that are used to transfer fluids to the waste handling systems outside containment, describe the action (automatic or manual) that is required to initiate fluid transfer.
If fluid transfer occurs automatically, describe the provisions that have been made to assure that any demand for fluid transfer will be overridden and that these lines will be automatically isolated in the event of an accident.
Furthermore, describe the provisions which will assure that the lines will remain isolated, even after resetting of the engineered safety features actuation signal.
Indicate the lines involved.
Response
Manual action is required to transfer fluids from containment to the waste handling systems outside containment.
After containment pressure and radiation have decreased below the isolation trip points on at least three of the four pressure and radiation sensors, containment deisolation may be accomplished by manual operation of two reset push buttons.
For lines isolated by the Safety Injection signal, the same requirements must be met for deisolation.
oc0679-0048a-46
- -~-~
The following lines are those which can transfer liquids and gasses to the waste handling system during power operation.
Service
- Containment Vent Header
- Clean Waste Receiver Tanks Vent
- Vacuum Degasifier Pumps Discharge
- Clean Waste Receiver Tanks Recirculating
- Pump Suction
- Clean Waste Receiver Tanks Recirculating
- Pump Discharge
- Clean Waste Receiver Tanks Pumps Suction Containment Air Sample
- Reactor Coolant Letdown
- Primary System Drain Tank Pump Suction
- Primary System Drain Tank Recirculation
- Primary Coolant Pumps Controlled Bleed Off Actuation CIS CIS CIS CIS CIS CIS CIS CIS CIS CIS CIS 4
- Containment Sump Drain
- Primary Coolant System Samples CIS (CHR Only), SIS CIS
- Quench Tank Vapor Sample CIS (c)
Identify the essential lines penetrating the containment; ie, lines which do not have a post-accident safety function yet are important to plant safety.
These lines typically do not receive an automatic isolation signal, or if they do, their isolati.on is deferred until subsequent signals are received that. confirm the existence of an accident condition.
Describe and justify the isolation actuation provisions for these lines.
(Exclude lines associated with the engineered safety features, and lines which are normally closed during operating modes requiring containment integrity and remain closed following an accident).
Response
The following essential lines are not isolated upon receipt of a containment isolation signal.
Instrument Air:
Compressed air is required after a DBA and the valves are designed to fail open to provide a supply of instrument air to controls inside containment.
(FSAR 9.5.2.1)
- Feedwater:
Required for heat removal.
- Component Cooling Water (CCW) Supply and Return:
CCW is required to permit operation of the PCPs.
At the present time, CCW is isolated upon receipt of SIS.
A modification to the isolation feature of these valves oc0679-0048a-46
is being made.
This modification (which is still under review and subject to change) will require a coincident SIS and a broken CCW line inside containment to initiate isolation of CCW.
Item 6.a, b and c Provide assurance that the operations, revisions and modifications which you have identified do not result in unsafe plant conditions.
Your reply should include special emphasis on maintaining reactor vessel integrity and on assuring accep~able containment integrity if containment isolation features are modified.
Response
5 The operations, revisions and modifications we have identified have been reviewed by the Plant Review Committee (PRC) and have been found to not result in unsafe plant conditions.
Operators are cautioned repeatedly in normal operating procedures and in training sessions not to violate pressure-temperature limits.
Based on. the above procedures and training, it is not anymore likely for an operator to violate the pressure-temperature limits while using these revised procedures than while using any other procedure.
Item 6.a Provide assurance that procedures and operator training include instructions that operators are not permitted to override engineered safety features.
Response
Operating procedures and training include instructions that Operators are' not permitted to override engineered safety features.
Once the safety injection signal has cleared and certain other parameters have been checked as described in Operating Procedure D-4.34; the Operator may reset safety injection.
Item 6.b Verify that the same criteria are used for continued operation of the charging pumps as those used for HPSI pumps.
Response
Consumers Power Company has determined that continued operation of the HPSI pumps after safety injection has been reset is not a desirable mode of operation (follow-up response to IE Bulletin 79-06B dated May 18, 1979).
oc0679-0048a-46
6 Likewise, continued operation of the charging pumps would only result in a greater amount of water passing through the Chemical and Volume Control System and would serve no purpose after safety injection had been reset.
We therefore do not intend to allow the continued operation of all charging pumps following the resetting of safety injection.
Item 6.d Document the indicators to be used in addition to pressurizer level for determining the condition of the PCS.
Response
See response to Item 2.a above.
Item 7 Provide assurance that:
(1) in response to the bulletin, you have verified all safety-related valves are properly positioned to ensure proper operation of engineered safety features, (2) valve positions, requirements and controls have been reviewed to assure proper operation of all engineered safety features, including systems not identified in your reply, e.g., containment air coolers, iodine removal system and hydrogen recombiners, and (3) routine periodic checks are made of valve alignment to assure that valves are in the required position.
Include the frequency of checking locked or secured valve positions.
Response
(1)
All safety-related valves have been verified to be properly positioned to ensure proper operation of the engineered safety features.
(2)
Valve positions, requirements and controls have been reviewed to assure proper operation of all engineered safety features.
(3)
Routine periodic checks are not made of valve alignments.
Valve alignments are generally performed following maintenance on a system or component and prior to start-up from the cold shutdown condition.
Item 9.a Provide assurance that redundant systems (as well as redundant equipment) are operable prior to removal of any safety-related component from service.
oc0679-0048a-46
t P~* _...
Response
The Equipment Outage Requests (EOR) require operational testing of redundant equipment prior to removal of any safety-related component from service.
An entire system check is not performed.
Item 9.c Provide assurance that procedures require the operation staff individual authorizing equipment maintenance, tests or surveillance which affect plant status to be an on-duty NRC licensed Senior Operator.
Also, describe the control of plant system status when shift changes are involved.
Response
7 Procedures require the duty Shift Supervisor to authorize all equipment maintenance, tests and surveillance which affect plant status.
The duty Shift Supervisor is an NRC Licensed Senior Operator.
Control of plant system status during shift changes is accomplished by use of a status board as well as a log book.
Both of these are reviewed prior to watch relief
- D P Hoffman (Signed)
D P Hoffman Assistant Nuclear Licensing Administrator R B DeWitt (Signed)
R B DeWitt Manager, Production-Nuclear CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement oc0679-0048a-46