ML18043B077
| ML18043B077 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/13/1979 |
| From: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 7910050126 | |
| Download: ML18043B077 (3) | |
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consumers Power company
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General Offices: 212 West Michigan Avenue, Jackson, Michigan 49201
- Area Code 517 788-0550 September 13, 1979 Mr Jam.es 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 - IE BULLETIN 79-06B -
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION DATED JULY 25, 1979
©lPW Reference (1): Letter from DPHoffman to JGKeppler dated August 10, 1979.
Reference (1) provided Consumers Power Company's response to the NRC request for additional information on IE Bulletin 79-06B dated July 25, 1979.
The NRC subsequently stated in a telephone conversation on September 6, 1979 that cer-tain of our responses were unacceptable.
These items are numbered 4, 6.b and 7 in all Bulletin 79-06B correspondence.
Having reviewed these most recent NRC positions, Consumers Power Company will commit to the following actions:
ITEM 4 We request that a licensed operator who has direct responsibility for control and operation of all main and auxiliary feedwater systems be in the main control room at all times.
We also request that the operator assigned to this function will, at the time of the transient requiring such action, take immediate control of the main and auxiliary feedwater systems, with no other concurrent responsi-bilities, until the steam generator levels return to a stable condition.
Response
An operator (licensed or unlicensed) will have direct responsibility.for control and operation of the auxiliary feedwater system during transient conditions requiring the use of auxiliary feedwater.
He will take immediate control of the auxiliary feedwater system during these transients, with no other concurrent responsibilities, until the steam generator levels return to a stable condition.
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2 We intend to continue operation in this. manner until the automatic initiation of auxiliary feedwater modification is complete, at which time we will no longer dedicate an operator to this function.
ITEM 6.b Your response to Item 6. b appears to be inadequate; therefore., provide assurance that operating procedures will be modified to keep high pressure injection and charging pumps in operation in accordance with the criteria specified in item
- 6. b of the bulletin and clarified by the following statement; "After 50F subcooling has been acll:ieved, termination of high.pressure safety injection (HPI) operation prior to 20 minutes is only permissible if it has been determined that continued operation would result in an unsafe plant condition, e.g., attaining pressure/temperature conditions that could jeopardize vessel integrity or that could have the potential for openi.ng the PORVs or safety valves so as to discharge water or a two-phase fluid consisting of water and steam."
Provide a schedule for completion of the review of operating procedures incorpor-ating such modifications as are necessary to comply with item 6.b of the bulletin.
Response
Consumers Power Company will revise operating procedures to keep high-pressure safety injection (HPSI) pumps in operation for 20 minutes following automatic initiation of safety injection.
However, we intend to reset safety injection when the conditions of Procedure D4.34 are met as described in Reference (1).
This will allow us to continue operating the HPSI pumps without injecting additional boric acid following an inadvertent actuation of safety injection.
Allowing the HPSI pumps to operate* for 20 minutes following an iBadvertent actuation of safety injection can result in a ruptured quench tank disc and in a substantial radwaste problem.
As for charging pumps, we cannot allow these to continue operating following an inadvertent actuation of safety injection.
We conclude that a safety con-cern exists since the letdown system will have been isolated and continued charging would result in a solid pressurizer and possible lifting, of the pressurizer safety valves.
Furthermore, we take no credit for charging pumps in any of the LOCA analyses.
CEN-ll4(P) (Small Break LOCA Analysis Report) has demonstrated that no credit need be taken for charging pumps following a small break LOCA.
The procedure we intend to follow will be to shut off the charging pumps when safety injection is reset, then reopen the letdown system isolation valve and finally restore letdown flow using one (1) charging pump.
Our procedures will be revised prior to reactor start-up following this refueling outage.
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3 ITEM 7 Your response regarding periodic checks of positions of uns.ecured valves is not acceptable.
We reg_uest that you modify your procedures to req_uire checks of the positions of unsecured valves monthly.
Response
Consumers Power Company will commit to locking all unsecured valves in engineered safety features systems which are not tested monthly.
The locks will be installed by January 1, 1980.
Until the locks are installed, we will position check these unsecured valves monthly during operation.
David P Hoffman (Signed)
Davis P Hoffman Assistant Nuclear Licensi_ng Administrator CC Director, Office Nuclear Reactor Regulation Director, Office of Inspection and Enforcement