ML18043B101
| ML18043B101 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/17/1979 |
| From: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Ziemann D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7910190375 | |
| Download: ML18043B101 (15) | |
Text
..
- e General Offices: 212 West Michigan Avenue, Jackson, Michigan 49201 * (517) 788-0660 October 17, 1979 Director, Nuclear Reactor Regulation Att:
Mr Dennis L *Ziemann, Chief Operating Reactors Branch No 2 US Nuclear Regulatory Commission Washington,* DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
REQUIREMENTS RESULTING FROM NRC STAFF REVIEW OF THREE MILE ISLAND 2 ACCIDENT -
COMMITMENTS ON NRC letter dated September 13, 1979, requested that Consumers Power Company agre.e to certain actions. that *evolved during NRC Staff review of the Three Mile Island (TMI) accident.
Specifically, Consumers Power Company was re-quested to commit. to implementation of the recommendations contained in NUREG-0578, "TMI-2 Lessons Learned Task* Force Status Report and Short-Term Recommendations", to installation of containment water level, pressure, and
- hydrogen monitoring equipment, to installatfon of remotely operable vents for reactor coolant system high 'points' and to upgrading of. emergency prepar-edness.
Detailed schedules for accomplishing these actions were included in the NRC letter.
ConsUJllers Power Company agrees that evaluation of the TMI accident indicates a need for c:ertain modifications to existing nuclear power plants and to methods of plant operation.
Consumers Power Company intends to comply with the recommendations cited in the September 13, 1979, NRC letter as they apply to the Palisade.s Plant in accordance with the specified schedules wherever
- possible.
The attachments to this letter provide a s~ary of Consumers Power Company's conmitments.
David P Ho fftnan Assistant Nuclear Licensing Administrator CC:
JGKeppler, USNRC
COMMI'IMENT TO TMI-2 LESSONS LEARNED RECOMMENDATIONS NURE~. G-0 57 8 Item Number/Subject 2.1.1 - Emergency Pover Supply Pressurizer Heaters Pressurizer Level PORV and Block Valve 2.1.2 ~ Relief & Safety Valve Test 2.1. 3.A - Direct Indication of Valve Position Commitment Required modifications and procedure changes will be completed by 1/1/80.
Pressurizer Level instrumentation meets the intent of criteria specified in NUREG-0578.
Some modifi-cations and documentation may be required to com-
.pletely qualify and will be completed as soon as equipment is available.
The Palisades Plant has two PORV and Block Valve combinations.
Both Block Valves meet criteria.
One PORV is not supplied from an emergency bus.
The power supply for this PORV vill be changed to an emergency bus by 1/1/80.
Based on FMEA perform-ed by CPCo, it has been concluded that "criss-cross-ing" the power supplies to the PORVs and Block Valves is less conservative than having each PORV powered from the same source as its Block Valve.
The EPRI program that is being developed will be responsive to the recommendations.
The program and schedule will be submitted to the NRC prior to 1/1/80.
Completion of all NRC recommendations are very dependent on the final scope of the EPRI program and resulting analysis.
Acoustical sensors will be provided for each PORV and Pressuriz.er Safety Valve.
Installation and calibration of equipment may hot be completed by 1/1/80 due to availability of hardware.
Modifi-cations will be completed at the first convenient cold shutdown after receipt of hardware.
Quali-fication as safety grade will be complete by 1/1/81.
2.,1. 3.B - Instrumentation for Emergency procedures fo.r prompt recognition of Inadequate Core Cooling void formation and. subsequence response was addressed via I&E Bulletin 79-06B (see letter CPCo to NRC Region III dated 8/10/79).
A complete set of procedures to be used by the operator to recog-nize inadequate core cooling will be de:ve+oped bas-ed on analyses being performed as required for Item 2.1.9.
The gUidelines for the procedures are being developed by the CE Owners Group and will be submitted to the NRC to establish generic resolu-ion before 1/1/80.
In addition to these commit-ments, Consumers Power is participating in a CE.
Owners Group to prepare a set of ftmctions' proced-ures on operators response to plant transients..
These procedures will initially assume a major
2-2.1.4 - Containment Isolation 2.1.5.A - Dedicated H2 Control Penetrations 2.1.5.c -
Recombiner Procedures 2.i.6.A - Systems Integrity for High Radioactivity malfilriction such as the loss of decay heat removal via the steam generators and then give the operator an alternative heat removal path.
Training on these procedures when developed will be via normal fifth shift training.
Monitoring of subcooling will be ensured by install-ation of two CE "subcooling" meters.
They will be powered from* preferred AC busses, receive tempera-ture signals from TM/LP, receive pressure signal from reactor overpressurization transmitters, have anmmciated alarms and read out in the control room.
Redundancy and separation requirements will be met by obtaining signals. and power from C and D RPS
'channels.
The installation schedule is dependent on deli vezy of the meters.
Engineering and procure-ment is underway and installation will be completed at the first convenient cold shutdown after receipt of hardware.
Procedure revisions and subsequent operator training will be via normal modification procedures and fifth shift training.
Palisades currently utilizes di verse parameters (CHP and CHR) to initiate containment isolation.
Modifications will be performed to assure that* one valve in each automatic isolation valve pair stays closed upon reset of the containment isolation sig-nal, thereby requiring deliberate operator action to reopen a containment isolation valve.
Modifi-cations will be completed by 1/1/80.
Consumers Power. Company does not use external re-combiners for post-accident combustible gas control; therefore, containment isolation systems for these recombiners are tmnecessazy.
Consumers Power Company presently has two Westinghouse electric
- hydrogen recombiners installed inside containment at Palisades.
These recombiners are seismically and environmentally qualified.
- Procedures for operation of the hydrogen recombiners*
are already in existence at the Palisades Plant.
Consumers Power Company has initiated a program to identify systems which could potentially contain radioactivity following an accident.
These systems will be inspected; and "leak detection and assess-ment" will be established by 1/1/80.
Actual test-ing to determine leakage and the performance of necessary corrective measures may not be complete by 1/1/80.
Results of our evaluation will be reported to the NRC.
3-2.1.6.B - Plant Shielding Review Consumers Power Company will initiate measures to adequately assure ~he protection of the health and safety of the plant work force during and after the postulated accident.
To this end, the follow-ing steps have been 1.mdertaken or are currently underway:
- 1. Identification of systems or areas outside tlie containment in addition to those specified in Section 2.1.6.a of NUREG-0578 with possible large.radiation fields after the postulated accident is currently being perfonned.
This
- analysis is expected to be completed prior to 1/1/80.
- 2.
Radiation dose calculations for all systems identified in 1. above using source terms out-lined in Regulatory Guide 1. 4 will begin by 10/20/79.
This analysis is expected to be completed by 1/1/80.
- At this time, direct doses from the containment to the control room, the* planned t~chnical support center and surro1.mding areas are expected to be less than 15 mR/hour.
Several options are currently under consideration to address those systems and areas where radiation doses are found to be prohibitively high.
One or a combination of these options will be chosen to assure that occupational radiation exposures dur-.
ing and after the postulated accident.remain with-in regulatory limits.
- 1.
Provide local or movable shielding in areas requiring continuous or frequent access. and identified as having a potential for abnormal-ly high radiation fields following the postu-lated accident.
Use of temporary movable shielding requires considering provisions for installation, pllis ingress and egress duiing installation..rt may be possible that this option may be implemented before 1/1/81; or
- 2.
Removal of equipment, instrumentation and sampling capabilities required during arid after the postulated accident into presently shielded locations *. This may still require ingress,/egress shielding. It is not likely that this can be totally implemented by 1/1/81.
Consideration will be given to the radiosensitivity of systems and components that are required to function in abnormally high radiation fields.
Materials or components not capable of withstanding these radiation levels.will be identified by 1/1/80.
Replacement materials, shielding or other actions to reduce doses to equipment will be identified and installed by 1/1/81, unless prohibited by hardware availability.
4-2.1.7.A - Auto Initiation of AJW 2.1.7.B -
AFW Flow 2.1.8.A - Post-Accident Sampling The AFW pumps control circuits will be modified to provide automatic start of the pumps upon tripping of the main feed pump turbines.
Automatic AJW flow control will be provided.
Class lE safety grade power supplies will be provided.
M::>difications will be completed by 1/1/80.
Equipment will be
- upgraded if necessary by 1/1/81.
Palisades currently has control grade AFW flow indication.
Safety grade S/G water level in.di-cation provides a di verse method of verifying AFW flow.
Safety grade flow indication will be install-ed incident to upgrading the AFW flow control sys-tem to meet safety grade requirements and com:plet-.
ed by 1/1/81.
Post accident conditions following a postulated loss of coolant (LOCA) of the type described in Regulatory Guide 1. 4 have been reviewed to deter-mine the capability of retrieving reactor coolant and containment air samples.
The present panel locations are accessible tmder accident conditions.
However, a shielded sample panel would be required with remote handling capabilities and a ventilation system to avo~d contamination of a habitable area of the plant.
Recycle capabilities will be con-.
sidered. Waste disposal or containment methods for old or tmused samples will be considered.
The existing sample lines may be adequate for. use tmder accident conditions, although isolation of these lines would occur and a manual override would be*
required.
There are two basic options for the location of the sample panel.
- 1.
Modify the existing sample panels to provide recirculation, shielding and handling provis-ions.
Due to space restrictions and inter-ference with normal operations, this may not be possible.
- 2.
InstalLa new sample panel at a different location to be used strictly for accident conditions.
This would probably be a more reasonable solution and would entail tapping into the existing sample lines and routing to the new location.
A low backgrotmd cotmting laboratory exists equipp-ed with a GELI system for spectral analysis and no problem is anticipated with the high backgrounds tmder accident conditions.
Boron and Chloride analyses are possible with existing equipment; however, evaluation* is needed due to the problems posed by the large activities present in the samples.
5-2.1.8.B - High Range Radiation Monitors Interfacing with Plant Shielding Review - Shield-ing for External Systems and implementation of the On-Site Operational Support Center may be required at a future date, but are expected to be minimal.
Date of compliance and speci fie details of design modifications and sampling techniques depend on the availability of vendor components, lead times, available technologies and completion of the plant shielding review.
Containment radi~tion monitors at Palisades can monitor up to 10 rad/hr.
Monitors capable of measuring the 107 rad/hr leVel are commercially available.
However, procurement and installation may prevent meeting the 1/1/81 completion date.
One vendor has indicated a lead time of one year and possiblY more.
The same situation exists for the noble gas e fflu-ent monitors.
Long lead times may prevent the installation of commercially available monitors by the 1/1/81 completion date.
Present noble gas monitors at Palisades can meas~ noble gas efflu-ents up to lo-3 uCi/cc (Xe-133).
Requirements for the high range monitors are as
- follows:*
Redundant:
Two physically separated units Seismic: Per R. G. 1. 97 Power:
Non-interruptible Specifications:. ANSI N320-1978 QA:
ANSI N45.2~1971 Display:
Continuous and recording Testing:
Per R.G *. 1.118 (on-line)
Commercially available system does not meet these
. additional requirements (may be qualified within one year) with the exception of various require-ments in ANSI N320 and R.G. 1.118. If the excep-tions.below are acceptable, installation may be accomplished by 1/1/81..
Due to excessive personnel exposure~ the calibra-tion requirements of R.G. 1.118 are not practical for the high end of the high range monitors (107 rad/hr).
We feel that if electronic online cali-bration is not acceptable, source calibration to 103 rad/hr for the direct radiation monitor, and to the first decade of the high range chamber of the multiple chamber, noble gas monitor should be utilized.
There are sections of ANSI N320 that are not appropriate to fixed high range monitors or noble gas monitors, in particular, Sections 8 and 9 which apply to environmental monitors and portable survey instruments, respectively.
6-2.1.8.c - Impr9ved Iodine Instrumentation 2.1.9 - Transient & Accident Analysis I
Containment Pressure, Water Level, Hydrogen Monitors(ACRS Item)
RCS Venting (NRC Manage-ment Added Item) 2.2.1.A*- Shif't Supervisor Responsibilities The Palisades Pl.ant presently has the adequate spectrum analysis equipment to accurately deter-mine airborne iodine concentrations.
Additional review is needed to determine adequacy tmder ac.cident conditions.
Existing procedures will be modified, additional training provided and necessary power supply dur-ing accident conditions provided.
Completion of these activities will not be complete tmtil March, 1980.
The response to the Transient and Accident Anal-yses reauirel'nents is being developed by the CE Owners Group in conjtmction with a generic resolu-tion meeting with the NRC staff.
These responses will be submitted by the Owners Group on the schedule required by the NRC staff and will be referenced for specific application to the Palisades Plant*.
Palisades currently has control-grade containment pressure (Range: 0-100.psi) and water le.vel instru-mentation (Range: 0-10 feet).
.These instruments will be upgraded to safety grade and the range modi-fied where necessary by 1/1/81.
Efforts to provide containment hydrogen monitoring capability are hampered by the inability to find an instrument which will function inside contain-
. ment during.accident conditions.
Routing of addi-tional lines out of containment is not. considered desirable.
A solution is still being sought.
Consumers Power Company is evaluating various al-temati ves for providing primary coolant system venting from the reactor ves$el and pressurizer.
Alternatives l.nlder consideration ineltide the use of the 3/4" vent line (P&ID M-201) or control rod drive mechanism mechanical seal (reference attach-ed CE report entitled, "CRDM Mechanical Seal Gas Leak Test") *as vent paths for the reactor vessel and the PORVs as a vent path for the pressurizer.
All necessary plant modifications will be complete by 1/1/81.
Consumers Power Company will review plant adminis~
trati ve and management procedures and revise, as necessary, to assure that reactor operations command and control responsibilities and authority are properly defined.. Corporate management will issue an operations policy directive emphasizing*
the duties, responsibilities and authority of the Shift Supervisor and the Shif't Technical Advisor.
All necessary actions will be complete by 1/1/80.
7-
- 2. 2.1. B - Shif't Technical Advisor Consumers Power Company will provide on-shif't Technical Advisors at the Palisades Plant.
These people will have a bachelor's degree, or equi va-lent, and will recf;!i ve speci fie training in the plant response to off-normal events and in acci-dent analysis of the plant.
All personnel have been selected and will start training on 11/1/79.
This program will be implemented by 1/1/ 80 and 2.2.1.C - Shif't. Turnover Procedure 2.2.2.A - Control Room Access 2.2.2.B -
On Site Technical Support Center 2.2.2.C - On Site Operational Support Center will continue until such time as CPCo determines that the Shi f't Technical Advisor function, as specified in NUREG-0578, is no longer necessary.
We will inform you of any alternative method of complying with the Shif't Technical Advisor function prior to our implementation of that method.
The procedures will be *developed and implemented by 1/1/80.
Controls will be developed and implemented by 1/1/80.
. Portions of the Control Room viewing area and office areas adjacent to the Control Room _will be dedicated for this function.
The center will be established by 1/1/80.
Upgrading to meet all requirements will be accomplished by 1/1/81 assum-ing availability of necessary hardware.
The* center will be established by 1/1/80.
COMMITMENT TO NEAR 'IBRM REQUIREMENTS FOR IMPROVING EMERGENCY PREPAREDNESS
- 1.
Upgrade emergency plan to Reg Guide 1.101 with special attention to action level criteria ba.5ed on plant para-meters.
- 2.
Implement certain short term actions recommended by Lessons Learned Task Force and use these in action level criteria.
- 3. Establish Emergency Operations Center. (EOC) for Feder~,
State and local officials
- a.
Designate location and alternate location and pro-Vi.de communications to plant
- b.
Upgrade EOC in conjunction with inplant technical support center This will be accomplish-.
ed by 1/1/80.
See responses. to items
- 2.1.8.A, 2.1.8.B and 2.i.8.c.
The EOC is located at the cPCo Conference Center 4 miles north of South Haven and 50% of communication in place at this time.
Alternate locations are:
State Police Posts at South Haven and Paw Paw and VanBuren County Sheri ff Department at Paw Paw.
Will be accomplished by 1/1/81.
v 8-
- 4.
Improve offsite monitoring capability
- 5.
Assure adequacy of State/Local Plans:
- a.
Against current criteria
- b.
Against upgraded criteria
- 6.
Conduct test exercises (Federal, State, local licensee):
- a.
Test of licensee's emergency plan
- b.
Test of State Emergency Plan
- c.
Joint test exercise of Emergency Plans (Federal, State, local, licensee)
Program requirements are being evaluated and will be established by 1/1/80.
Hardware needs to be identi-fied by 1/1/80.
State and local plans com-pleted and submitted to NRC Region III Will be accomplished by mid-I 80 1S, Will be accomplished by 1/1/81.
Will be accomplished by mid-' 80 's.
Will be accomplished by mid-1 80 1 s.
- Will be accomplished within 5 years.
/
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- 1-Prepared Reviewed Document
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ATTACHMENT l COMBUSTION ENGINEE?.ING DEVELOPMENT DEPARTBENT Test Report CRDM MECHl\\NICAL SEAL GAS LEAK TEST 601454 I*
- ~;;//{4 c..11.l~ e !.... :
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Approved by:
~-- c /tC,. u..&Y I
M. P. Chaplin Laboratory ~lanager e_ 1e/ ;1;( /.'f--2~
Supervision TR-ESE-347 Date of Issue:
/_vk/79 I
Reference:
Test Request A99
J I.
II.
INTRODUCTION A test was performed to dete~mine the ability to vent lighter than air gases through the control rod drive mechanism mechanical face seal.
This report details the testing performed using helium with a production type seal in a simulated CRDM seal housing.
SUMMARY
The mecha~ical face seal.utilized in the rack and Pinion type control rod drive mechanism vented the lighte~ than air gases during both static and rotating modes of opera~
tion.
Gas vented through the seal at B rate. of approxi-mately 20 ml/min. at 2100 psig and 232 F.
At pressures less than 2100 psig, the rate of leakage increased with 2400 ml/min. occuring at 1000 psig.
When* the gas is backed with borated water, venting was continuous uhti1 the gases w~re removed.
At this time, the seal retained the system water at pressure.
III.
DISCUSSION The* Nuclear Labora.tories seal test facility for this test.
The test section (Figure 1) the lower section of *the CROM seal h6using.
vessel below the seal provides pressure ~nd to the borated water within. the ~essel.
was utilized simulates The test temperature The seal utilized for the testing was a pre-production qualification seal.
The test water was demineralizeq water borated to.900-1200 ppm.
The gas used was commer-cial grade Helium.
The test seal ~as lapped ahd hydrostatically tested at 2100 psig.
- No leakage wa~ observed.
The facility was heated to 2S0°F at 2100 psig using water to maintain the pressure.. After a 30 minute stabilization at temperature, the water was drained from the syst~m leavin~ a ~team at-mosphere in the test vessel.
Helium was introduced until a cavity pressure of 2100.psig was obtiined.
The s~al leak~ge part of the test vessel was routed throug~
a water seal to a* graduated water f ille.d beaker. *A seal leakage rate could then be established by water displace-ment~. (See test setup - Figure 2).
1 -
TR-ESE-347
The gas pressure on *the seal was decreased at 3 minute intervals down to a point at which leakage exceeded the capacity of the system to maintain cavity pressure.
Table I details the leakage at the various pressures.
The gas leak test was performed both with the seal rotating and static.
At the completion of the test, the vessel was pressurized to 2100 psig with demineralized water.
This operation formed a Helium bubble backed with water at the seal.
. Gas leakage at this condition was observed coritinuously at 20 ml/min. until the water had displaced the gas.
The seal leakage then stopped and no water *leak was ob-served.
IV.
CONCLUSION This test has determined that the test CROM mechanical face seal vented lighter than. air gases undei pressura and lo~ temperature conditions.
The fact that the greatest leak rates occured at or below 1200 psig indicates that the seal faces would open slightly due to seal *balance at the
.lower pressures.
The tests were performed several times with the same seal, the leak rates in Table 1 are the av~rage of all tests.
The seal utilized for the testing had accumulated 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> of operation with leakage never*exceeding*S cc per hour.
No attempt was made to deteirnine whether air could be vented
.through the seal oi to determine if leakag~ oth~r~than across the seal faces was *occuring~ The test was petforci~d utilizing calibrated gages and tempera~ure readouts, but was not per-formed in accordance with existing Quality control Requiremen~s.
2 -
TR-ESE-347.
Pressure PSIG 2100 1800 1600 1400 1200
- tooo 800 600 400 300 232 223 217
.. 215 214 210 Static Tl\\13LE 1 Leak Rate ml/min; 20
- 18 24 32 48 2400 3 -
Unable Temp.
- O F 227 221 214 213 210 to Hold Rotating Leak Rate ml/min.
45 16 45 80
.720 Pressure TR-ESE-347
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