ML18044A769
| ML18044A769 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/16/1980 |
| From: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Ziemann D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8004210158 | |
| Download: ML18044A769 (3) | |
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consumers Power company General Offices: 212 West Michigan Avenue, Jackson, Michigan 4g201
- Area Code 517 788-0550 April 16, 1980 Director, Nuclear Reactor Regulation A.tt Mr Dennis L Ziemann, Chief Operating Reactors Branch No 2 US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 -
LICENSE DPR-20.
PALISADES PLANT -*
SUPPLEMENT TO WATER RAMMER TESTING Consumers Power Company requested an amendment change for the Palisades Plant operating license on April 11, 1980, in order to conduct a feed~ine water harni:ner test (Palisades Spec.ial Test Procedure T-130).
As a result of an NRC review of the subject amendment, the following information was requested.
. Our lette.r dated September 22, 1978, committed to administrati"ve limits of 150 gpm flow rates of auxiliary feedwater feeding to each steam generator.
- From operating experience, this flow rate is *unacceptable.
For example, it.
has been exper.ienced that on a reactor trip due to low steam ge~erator level, level indication went off scale.
The operator feeding at a flow rate of 150 gpm does not ?,now how far off scale he is, therefore, operating in* an. unsafe condition.
To eliminate this potential problem, we would like to increase our feed rate which would increase the recovery rate and avoid the potential of l~sing level indication.
In order to do this, a test should be conducted (Pro-c.edure T-130) to verify that a water harnrrier will not occur at a different now rate.
The procedure basically consists of:
( l) lowering th*? water level of the steam generator being tested to below-the spari.ger ring; ( 2) letting the. sparger and feedline d.n1in ( approx::i.mately five minutes); a..:..id ( 3) startif1g to increase water level in* the steam generator under pre-determined pressure and flow rates.
WhD,e performing the test, the operators will monitor for a water hammer.
If a water hammer should res1.1lt, the test will be stopped immediately.
The Palisades Plant ReviewCommittee (PRC) concluded that this test (feedline water hammer) was an unreviewed safety question as defined by 10 CFR 50.59(a)(2)(i) which states, "A propo1ed change, test, or experiment snall be deemed to involve an unreviewed safety question ( 1) if t~1e :probability of occurrence
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- supplement to Water Hammer Testing April 16, 1980 or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report may be increased; or... ".
2 Applying this statement to the feedline water hammer test, one can $ee that there
- would be an. increased probability of occurrence or the consequence of an accident or malfunction of equipment important to safety previously evaluated in the FSAR.
However, performing this test: will not have an adverse impact on the healtb. and safety of the public or plant personnel because of the following:
l) Palisades Plant has been shut do:wn since September 7, 1979, which accounts for:
a) b)
c) virtually no decay heat in the reactor; the primary coolant activity is only 2 x lo-2 ).lCi/gm which is a factor of 104 below that.. the* Technical Specification limit of 100/E ;iCi/gm; the secondary side tgtal activity is ~ lo-7 jl.Ci/gm* which is at*-
least a factor of 10 below the Technical Specification.limit of 0.1 JlCi/gm (Iodine. dose equivalent).
- detection capability.is ~ lo-7 )lCi/gm
- 2)
If. a water hammer would occur, it would p~obably happen during.the 200 psi test rather* than the* 900 psi test.* This pressure is much less than the design rating of the piping.
3). Of all water ha.miners experienced in the industry (US), only one has result-ed in a pipe break.
This was at Indian Point where a water ha.IDmer broke a steam generator feedwater line.
The line was broken as a result of repeated water hammers at full pressure conditions.. If a water hammer does occur during a full pressure test, the test will not be repeated.
- 4)
Operators will be specifically prepared to handle a feedwater line break should one happen.
- 5)
In the event of a feedwater line break, the core can be cooled down by any one of the following systems:
a) normal makeup and letdown, b) water inventory from the other steam generator' c) shut down the PCPs to stop the only heat source being used, d) high pressure safety injection and PORVs, e) low pressure safety injection.
Supplement to Water Hammer Testing April 16, 1980 Based on the foregoing, Consumers Power Company has concluded that performance of the test does not involve a significant hazard consideration with respect to potential impact on the health and safety of the public.
David P Hoffman Nuclear Licensing Administrator CC JGKeppler, USNRC Resident Inspector-Palisades 3