ML18046A795

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Requests That Util Make Application for Tech Spec Changes to Require Time Response Testing of All Safety Sys Resistance Temp Detectors within One Month of Operation for Newly Installed Resistance Temp Detectors
ML18046A795
Person / Time
Site: Palisades Entergy icon.png
Issue date: 06/30/1981
From: Crutchfield D
Office of Nuclear Reactor Regulation
To: Hoffman D
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
LSO5-81-06-126, LSO5-81-6-126, NUDOCS 8107160256
Download: ML18046A795 (5)


Text

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Docket No. 50-255 LS05-81-06-Jl26 June 30, 1981

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Mr. O_avid P. Hoffman Nuclear licensing Administrator*

Consumers Power Company JUL 0 7 1981 a.

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U, 1, NUQ.IAR RIO!ll'JPP 1945 ~r:* Partial l Road Jackso~, Michigan 49201

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Dear Mr. *Hoffman:

  • By letters dated April 25, 1978 and August 29, 1979, Florida Power and light Company and Northeast Nuclear Energy Company provided techriical reports on two different Loop Current Step Response (LCSR) methods for detenniriing the resistance temperature detector (RTD) response time at St. Lucie, Unit No. 1 and Millston~, Unit No. 2-,.respectively. These methods are similar in most _

respects, but-have a few differences which are dhcu$sed in the enclosed Safety Evaluation (SE).*. Based on our review of both reference reports, we find the LCSR methods to detennine RTD time response as described in each report and documented 1n the SE to be acceptable.

We plan to issue the SE as a NUREG in. the near future.

Extensive testing has shown the LCSR method to be :extremely reliable and provide results with an accuracy,_o_f 10% (maximum error). This compa*res very favorably with the *older plung~ test rneth_od, which often has inaccuracies as high as a factor of 3. Since"the LCSR methodotfers a significant improvement in RTD response time testing, we recommend you consider its use at your f aci 1i ty. It appears to us that use of the LCSR *method* would a.l so result in a reduction in persoonel-radiatfon exposure.

~~

. Th~ten-s-1-veRTO time response testing which has been don,~rin conjunction

  • ____.-*-.*"\\'11th the development; of the LCSR method has revealed that the RTDs in operating reac~ors suffer time. response degradation as they age.

Current Standard Technical Specifications (STS) require that one quarter of tha~**,safety system" RTDs be tested each 18 months.

This corresponds to testing ~ach RTD once every six years.

In view of the RTD time response degradatfon observed in our study, ft 1 s.cl ear that the present RTD survei 11 ance testing schedule is

./' not *adequate. *we request that you make application for TS changes to require

/

the time. response testing of all safety system RTOs within one month of operation for newly i:nstalled RTD and once every 18 months thereafter. This application should be made before or as a part of your application for the next core reload.

If you p.lan to use the provisions of 10 CFR 50.59 for the next core.

reload, pl ease submit the application for such a change at least 90 days ahead of the next planned reactor shutdown.

This request is independent of*

whether you plan to use the LCSR or some other method.(plunge test for example) of determining the RTD response time.

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OFFICE*' ( ~A2' lt8~~b Og5g3gg5 1!~ *i

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SURNAME.,:

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NRC !"ORM 31811El/8E>l NRCM i>2"4()

OFFICIAL RECORD COPY

  • *usGPO: 1980-329-824

OFFICE~

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In this review, it has come to our* attention.that your facility TS do not include limiting condition for operation (LCO) and surveillance requirements (SR) for engineered safety features response time of each ESFAS function.

You are requested to propose such LCOs and SRs, as necessary, in the same time frame as for the 18 month response testing. The current STS pages of interest are enclosed..

If you have any questions on this subject, please contact your assig~ed NRC project manager.

Enclosures:

As stated cc: See next page DISTRIBUTION:

Docket File NRC PDR L PDR NSIC

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Sincerely, Is}

Dennis M. Crutchfield, Chief Operating Reactors Branch #5 Division of Licensing

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>..!RC FORM 318 1101801 NRCM 02"4>

OFFICIAL RECORD COPY

  • USGPO: 1980-329*824

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 June 30, 1981 Docket No. 50-255.

LS05-81-06-l26

/

/

Mr. David P. Hoffman Nuclear Licensing Administrator Consumers Power Company 1945 W. Parnall Road Jackson, Michigan 49201

Dear Mr. Hoffman:

By letters dated April 25, i978 and August 29, 1979, Florida Power and Light Company and Northeast Nuclear Energy Company provided technical reports on two different Loop Current Step Response (LCSR) methods for determining the

.resistance temperature detector (RTD) response time at St. Lucie, Unit No. 1 and Millstone, Unit No. 2, respectively. These m~thods are similar.in most respects, but have a few differences which are discussed in the enclosed

Safety Evaluation (SE).

Based on our review of both reference reports, we find the LCSR methods to determine RTD time response as described in each report and documented in the SE to be acceptable.

We plan to issue the SE as a NUREG in the near future.

Extensive testing has shown the LCSR method to_be extremely reliable and

  • provide results with an accuracy of 10% (maximum error). This compares very favorably with the older plunge test method, which often has inaccuracies as high as a factor of 3.

Since the LCSR method offers a significant improvement in RTD response time testing, we reconime~hd you consider its use at your facility. It appears to us that use of the LCSR method \\'JOUld also resul~

in a reduction in personnel radiation exposure.

The extensive RTD time response testing* which has* been 'done in conjunctjon with the development of the LCSR method has revealed that the RTDs in o~er~ting

  • reactors suffer time response degradation as they age.

Current Standard Technical Specifications (STS) require that one quarter of the safety system

  • RTDs be tested each 18 months.

This corresponds to testing each RTD once

  • every six years~ In view of the RTD time response degradation observed in our. study, it is cl ear that the present RTD surveillance testing schedule is not adequate.

We request that you make application for TS changes to require the time response testing of all safety system RTDs within one -month of operation

  • for newly installed RTD and once every 18 months thereafter. This application should be made before or as a part of your application for the next core rel-0ad.

If you plan to use the provision~ of 10 CFR 50.59 for the next core reload, please submit the application. for such a change at least 90 days

  • ahead of the next planned reactor shutdown.

This request is independent of whether yo~ plan to use the LCSR or some other method _(plunge test for example) of determining the RTD response time.

....; c-June 30, 1981 In this review~ it has tome -to our attention that your facility TS do not include limiting condition for operation (LCO) and surveillance requirements (SR) for engineered safety features response time of each ESFAS function.

You are requested to propose such LCOs and SRs, as necessary, in the same time frame as for the 18 month response testing. The current STS pages of.

interest are enclosed.

If you have any questions.*on this subject, pl ease contact your assigned NRC project manager.

Enclosures:

As stated cc:. See next page.

Sincerely, Dennis M. Crutchfield, C 'ef Operating Re.actors Branch -#5 Division -0f Licensing

Mr. David P. Hoffman cc M. I. Miller, Esquire Isham, Lincoln & Beale Suite 4200 *

'one First National Plaza Chicago, Illinois. 60670 Mr. Paul A. Perry, Secretary Consumers ? ow er Com,Jany 212 West Michioan Avenue Jackson, Michi~an 49201 Judd L. Bacon, Esquire Consumers Power Co~any 212 West Michigan Avenue Jackson, Michigan 49201 Myron M. Cherry, Esquire Suite 4501

  • one IBM Plaza Chicago, Illinois 60611 Ms. Mary P. Si nc la i r Great Lakes Energy Alliance 5711 Sum.merset 'Drive Midland, Michigan 48640 Kalamazoo Public Library 315 South Rose St~eet Kalamazoo, Michigan. 49006 Township Supervisor Cove rt Township Route 1, Box 10
  • Van Buren County, Michigan Office of the Governor (2)

Room 1 ~Capitol Building

  • Lansing, Michigan 48913 William J. Scanlon, Esquire 2034 Pauline Boulevard Ann Arbor, Michigan 48103 Palisades Plant ATTN:

Mr. Robert Montross Plant Manager Covert, Michigan 49043 49043 3 -

June 30, 1981

u. s. Environmental Protection Agency Federal Activities Branch Region V Office ATTN:

EIS COORDINATOR 230 South Dearborn Street Chicago, Illinois* 60604 Charles Bechhoefer, Esq.,. Chairman*

Atomic Saf~ty and Licensing Board Panel

u. s. Nuclear Regulatory Corrrnission Washington, D. c.

20555 Dr. George C. Anderson Department~' of Oceanograp-hy.

University of Washington Seattle, 'Washington - 98195 Or. M. Stanley Livingston 1005 Calle Laroe Santa Fe, Ne~ ~exic6 87501 Resident Inspector c/o U. S. NRC i'. o. Box 87