ML18046A664

Forwards Comments on NRC 801112 Draft Evaluation of SEP Topic VI-7.F Re Accumulator Isolation Valves Power & Control Circuit Design.Util Disagrees That Restoration of Tank Capability Will Be Problematic

ML18046A664
Person / Time
Site:	Palisades
Issue date:	05/19/1981
From:	Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Crutchfield D Office of Nuclear Reactor Regulation
References
TASK-06-07.F, TASK-6-7.F, TASK-RR NUDOCS 8105220380
Download: ML18046A664 (6)

Text

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• General Offlcea: 212 Wen Michigan Avenue, Jackson, Michigan 49201 * (517) 788-0660 May 19, 1981 Director, Nuclear Reactor Regulation Att Mr Dennis M Crutchfield, Chief Operating Projects Branch No 5 US Nuclear Regulatory Commission Washington DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - SEP TOPIC'VI-7.F - ACCUMULATOR ISOLATION VALVES POWER AND CONTROL CIRCUIT DESIGN By letter dated November 12, 198.0, the NRC transmitted for comment a draft evaluation of SEP Topic VI-7. F for the Palisades Plant. Consumers Power Company has completed a review of this draft evaluation and has developed several comments pertinent to this topic. These comments are provided for*

NRC consideration as an attachment to this letter.

David P Hoffman Nuclear Licensing Administrator c.::;: Director, Region III, USNRC NRC Resident Inspector-Palisades att (5 pages )_

• 8105220~~

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PALISADES PLANT COMMENTS ON NRC TECHNICAL EVALUATION -- - ---- -- --- -- - ---------

SEP TOPIC VI-7.F Summary of the SEP Evaluation The objective of the sp Evaluation was to determine if the safety injection .

bottle isolation valve power and control system is in compliance with current licensing criteria. According to the evaluation, branch technical positions ICSB 4, "Requirements On Motor-Operated Valves In The ECCS Accumulator Lines" and ICSB 18, "Application of the Single Failure Criterion to Manually-Controlled, Electrically-Operated.Valves" serve as the basis for. current licensing criteria.

In summarizing its evaluation, the Nuclear Regulatory Connnis.sion (NRC) has stated that the Palisades safety injection bottle isolation valve power and control system design deviates from current licensing criteria in the following three areas:

1) The design meets the requirements of ICSB 18, Part 2 with the exception that plant Technical Specifications do not specify by number the valves to be opened and de-energized.

2) The design does not conform to ICSB 18, Part 4 which should be complied with when removal of valve motor power is used to meet the single-failure criterion. ICSB 18, Part 4 states "When the single-failure criterion is satisfied by removal of electric power from val v.es described in 2. and 3.

above, these valves should have redundant position indica-tion in the main control room and the position indication system should, itself, meet the single-failure criterion."

According to the evaluation, "only one position indicator per valve is available in the control room, *a scheme which is inherently single-failure prone."

3) The location of the valve motor breakers inside containment poses problems in restoring the safety injection bottle isolation capability if necessary.

Evaluation Comments Comment #1 Paragraph 3 .1 of the SEP evaluation states that the method of removing power from the valve motors (e.g., open breaker, rack-out breaker or disconnect motor power cables) is not specified in the Palisades Technical Specifications.

In reality, the Technical Specifications clearly describe the method of dis-connecting power. Page 3-33 of the .Technical Specifications (Paragraph #3) states: "The inadvertent closing of any one of the safety injection bottle isolation valves in conjunction with a LOCA has not been analyzed. To provide assurance that this will not occur, these valves are electrically locked open by a key switch in the control room. In addition, prior to critical, the valves are checked open and then the 480V breakers at MCC 9 are opened. Thus, a failure of a breaker and a switch are required for any of the valves to close.

Comment #2

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indicate that the Palisades safety injection bottle valve power and control system design deviates from current licensing criteria is part due to breaker location. The evaluation states that the valve breakers are located inside containment. Paragraph 3.2 of the evaluation specifically states that the breaker location poses problems in restoring safety injection bottle capability if necessary. A review of the applicable drawing (M-5, Rev 5, attached) verifies that the valve breakers, located in motor control center MCC-9, are inside contain-ment.

The conclusion that the Palisades system arrangement and design does not comply with current licensing criteria and poses problems in restoring tank capability is incorrect for the following reasons:

1) Of the current licensing criteria itemized in Section 2 of the SEP.evaluation, only branch technical position ICSB-18, Part 3, somewhat pertains to this issue. Part 3 states that "active" valves should not be included among those valves from which power is removed in order to meet the single-failure criterion. Part 3 further states that power can be removed if it can be restored to the valves from the main control room. It should be noted, however, that the Palisades valves are not "active" valves in that they are not required to open or close in any safety sys-tem operational sequence. No other current licensing criteria, as itemized in Section 2.0, applies to this issue.

2) The. specific breaker location does not pose problems in restoring safety injection bottle capability, if required.

Should containment entry be possible, the tanks can be isolated by manually closing the motor-operated isolation valves with hand. cranks. In addition, safety injection tank nitrogen can be vented from the control room, regard-less of containment conditions, to eliminate the driving force behind the bottle's water volume.

At 1 1/2 to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> following a small break LOCA, and definitely before proceeding in to the shutdown cooling mode, present procedures (CE generic recommendations from post TMI small break LOCA reanalysis efforts) call for the safety injection tanks to be either isolated or vented.*

Palisades has chosen the vent option and the tank vent valves are being qualified to containment post LOCA conditions.

Deviations from Review Criteria Deviation #1 The Palisades Technical Specifications do not comply with licensing criterion ICSB-18, Part 2. The specifications do not include a specific list of all '

electrically-operated valves to which the requirement for removal of electric power is applied in order to satisfy the single-failure criterion.

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Deviation #2 The safety injection bottle _n:iotQ!'~.Qp_erated_ isolation--va-1 ve design does--not compl.y-with bra.rich--technical position ICSB-18, Part 4. The valves do not have redundant position indication in the control room. In addition, the existing position indication system is not single-failure free.

Justification of Acceptability for Deviations Deviation #1 A specific list of electrically-operated valves, for which the removal of electric power is applied to satisfy the single-failure criterion, is not given in the Technical Specifications. In the case of the safety injection bottles, however, the specifications do provide a detailed description of the valves, their reqi.lired position and the method of disconnecting power to their'motors. Technical Specification 3.3.1.i (Page 3-29) states: "The Safety Injection bottle motor-operated isolation valves shall be opened

• with the electric power supply to the valve motor disconnected." Page 3-33 of the specifications supplements this description as describ.ed in the corrections portion of this review.

Although the NRC has taken the position that the Palisades Technical Speci-fications do not comply with current criteria because they do not contain a specific list of valves, nor are the valves identified by numer, the above description provides a clear account of which valves are to be opened and the method of lock out. The specification description leaves virtually no doubt as to which valves are being addressed'since:

1) the valves are functionally identified as "Safety Injection bottle motor:.:..Operated isolation valves,

2) the motor control center that supplies power to the valve motors is identified numerically and

3) there are no other motor-operated valves in the safety injection bottle piping system (refer to attached P&ID M-203, Rev 18). We, therefore, conclude that the omission of speci-fic valve numbers from Technical Specifications is acceptable and not a relevant safety concern.

Devi a ti on #2 Although it is true that the valve position indication for the safety injection bottle motor-operated isolation valves1 is riot redundant, it does not follow that the Palisades arrangement is inherently single-failure prone. Plant operating procedures implement Technical Specifications by reqi.liring that prior to making the reactor critical: 1) these valves to opened, 2) the hand switches in the control room be key-locked open and 3) the 48ov breakers be opened and locked. It should be noted that the valve position indicating system is powered from a separate d-c bus and is, therefore, in service even though the valve's breaker is open (refer to attached schematic diagrams E-243, Sh 1, Rev 4 and E-243, Sh 2, Rev 0). It is, therefore, concluded that the arrangement and design of the safety injection bottle motor-operated isolation valvesl are acceptable, and not relevant safety concerns.

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