ML18046A815
| ML18046A815 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/22/1981 |
| From: | Vincent R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| TASK-05-10.B, TASK-05-11.A, TASK-05-11.B, TASK-07-03, TASK-09-03, TASK-5-10.B, TASK-5-11.A, TASK-5-11.B, TASK-7-3, TASK-9-3, TASK-RR NUDOCS 8107280197 | |
| Download: ML18046A815 (6) | |
Text
consumers Power company General Offices:.212 Wast Michigan Avenue, Jackson, Michigan 49201 * (517) 788-0550 July 22, 1981 Director, Nuclear Reactor Regulation Att Mr Dennis M Crutc.hfield, Chief Operating Reactors Branch No 5 US Nuclear Regulatory Commission
-Mashington; DC *20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - SEP TOPICS V-10.B V-11.A, V-11.B, Vll-3 AND IX-3 SAFE SHUTDOWN SYSTEMS)
By letter dated November 5, 1980, the NRC transmitted for comment a draft evaluation of the Safe Shutdown Systems Review for the Palisades Plant.
Consumers Power Company has completed a review of this document and provides the attached comments for your consideration.
Evaluations for Topics V-11.A, V-11.B and IX-3 were transmitted separately from the above report and have previously been commented on in CPCo letters dated July 3, 1981, May 15, 1981 and July 7, 1981 respectively.
Comments on these topic evaluations are not repeated here, although they should be considered in any changes which may be made to the Safe Shutdown Systems Report.
In addition, the NRC transmitted the electrical and instrument & control portion of the safe shutdown systems review by separate letter dated January 24, 1981.
The attached comments also do not include our comments on that E and I&C portion.
Although our review of this portion of Topic VII-3 is still in progress,.we do expect to have substantive comments, particularly with respect to the minimum list of Safe Shutdown instruments in Table 3.3.
We expect to have our* comments submitted by July 31, 1981.
Robert A Vincent Staff Licensing Engineer CC Director, Region III, USNRC NRC Resident Inspector - Palisades I 8107280197 810722 i, *1 r\\
l ~DR AD~~K 05000~5~ L
... J
/
PALISADES PLANT ~ SAFE SHTJrDOWN SYSTEMS SEP TOPICS V-10.B, V-11.A, V-11.B, Vll-3 AND IX-3
-~~.
- *'REVIEW.COMMENTS Section 2.1
- 1. First paragraph,. second sentence shoUld read:
"The plant uses GOP 8, Plant Shutdown to Hot. Standby/Shutdown for this purpose."
- 2.
Second paragraph,. first sentence:
auxiliary loads are transferred from station transformer to startup transformer when power reaches 20%.
Seventh sentence:
GOP 8 does not instruct the operator to trip two pumps at this point.
- 3.
Third paragraph, fir*st sentence ihoUld read:
"The plarit is shut down from hot standby to the cold shutdown condition u5ing plant procedure GOP 9, Plant Cooldown from Hot Standby/Shutdown."
- 4.
Fourth paragraph, second sentence:
The cooldown rate is administra-tively limited to 6o°F/hr, al though rates up to l00°F/hr are permitted by plant technical specifications.
- 5.
Fifth paragraph, first sentence:
Shutdown cooling is placed :i,.n opera-tion after reaching 250 psig according to GOP 9.
Section 2.2 *
- 1.
First paragraph, third sentence:
These loads include service water pumps, charging pumps and containment air cooler fans.
- 2.
Last sentence:
The auxiliary feedwater steam-driven pump is automat*
ically aligned and started to feed the steam generators; the motor-driven pump may be manually started on emergency bus 1-C should the turbine-driven pump not start.
Second paragraph:
Palisades has only one turbine bypass valve.
Third paragraph:
Plant procedure D.4.3 is now EOP2; procedure A.5.9 is now GOP 9.
.§_ection 3. 2 * -
- -L * -*Page 18, first paragraph, *second arid third sentences: -- The control rods are ~tually powered from the preferred ac buses.
- 2.
Fourth and fifth sentences:
These should be deleted or revised to reflect power sources for the preferred ac buses.
P~ge 20, last paragraph:* There are five two-inch PCS drain lines -
four between the steam generators and the pumps and one off the hot leg.
- 3.
Page 22, third paragraph:
With the reactor vessel head removed,
,. -adequate, cooling,can.be.. ;provided by.. keeping.the. core flooded with LPSI and HPSI but probably not CVCS.
2
- 4.
Page 26, first sentence should read:
"One of the four atmospheric dump valves which are set up for automatic operation and remote manual control from the control room, has sufficient capacity for maintaining hot shutdown or for cooldown of the primary coolant system (PCS)."
- 5.
Page 26, second paragraph:
Palisades has only one turbine bypass valve.
- 6.
Page 27, Feedwater:
Both main feedwater and both condensate pumps are used under normal operating c.onditions above about 40% reactor power; one main feedwater and both condensate pumps are used below 40%.
Second paragraph, sixth sentence:
The 6" bypass valves are mechanically
- disabled in the closed position with.air s.upply removed.
- 7.
Page 28, first sentence should read:
"There is no leak detection system provided for the AFS pump room to provide timely warning to the opera-tors that a severe AFS leak or flooding condition exists in the room, although an auxiliary operator checks the room at least once per shift."
Second paragraph, 11th sentence:
The normal steam generator inventory will provide decay heat removal for approximately one hour following reactor trip from full load assuming no change in PCS average temperature.
- 8.
Page 29, second paragraph, second sentence:
- The implication that the heater drain pumps can receive power from the diesel generators is incorrect.
Breaker interlocks preclude supplying the lE bus from lC or lD when their respective diesel generator output breakers are closed.
- 9.
Page 31, second sentence:
A control and instrument air failure would not disable the flow path from the Boric Acid Tanks via the Boric Acid Pumps.
The.path via the Boric Acid Pumps and motor-operated valve M0-2140 is independent of the instrument air system.
Fourth sentence:
No procedures presently exist to manually open the auxiliary spray valve inside containment in the event of loss of instru-ment air.
Table 3.1
- 1.
The information under the Quality Group and Seismic headings were not verified.* These are being addressed under Topic III-1.
- 2.
Component Cooling System valve list should include CV-0949.
Table 3.2
- 1.
Item 3.e should read:
Steam Generator Blowdown Lines
.,._Tablt:!...,3.. J
- 1.
Primary Coolant System:
Under pressurizer pressure, wide range pressure transmitters PT0103 and PT0104 should be included.
Under PCS temperature, TEOlll A, B and HSOlll should be included.
3
- 2.
Emergency AC Power:
There are no bus energized lights in the control room for 480 v buses 11, 12 and MCC 1, 2, 7, and.8.
- 3.
Emergency DC Power:
There are no bus energized lights.
There are, however, voltmeters and loss of power alarms in the control room.
Table 3.4
- 1.
All references to Reactor Building should be changed to AU:Xiliary Building.
Section 4.1
- 1.
Page 49, second paragraph, second sentence should read:
"The SCS is isolated from SI tank pressure (200 psig) by one check valve and one LPSI motor-operated valve in each cold leg injection path,"
- 2.
Page 51A, first sentence should read:
"In generic letter of February 23, 1980, the NRC requested all licensees to identify the following* valve configurations which may exist between the PCS and*low pressure plant systems extending beyond containment:
- 1).. *.. "
- 3.
Page 52, next to last sentence:
The resulting pressure increase is sensitive to the steam generator to PCS temperature differential; an increase in the temperature differential will increase the resulting pressure.
- 4.
Page 55, first paragraph, last sentence:
The shutdown.cooling system may be used for small break LOCAs in which the safety injection system is capable of refilling the primary coolant loop, however, the capadty of RV-3164 is insignificant compared to normal shutdown cooling flow rates.
- 5.
Page 55, second paragraph:
Consumers Power Company has not explicitly
- evaluated the radiological consequences o.f SCS heat exchanger leakage during post-LOCA recirculation of CSS flow.
- section 4.3
- 1.
Second paragraph, second sentence should read:
"Each SCS (LPSI) pump has a mini-flow recirculation line which returns a small portion of the pump discharge fluid to the SIRW tank."
Fifth sentence:
Note that the SCS (LPSI) pumps are not used in the post-LOCA recirculation mode.
4 Section-4.6
- 1.
,.Tec:t+nical spec;ifications require.th.at ;100,000 gallons be maintained in the CST and T-81.
As such the low level alarm on the CST (T-2) is set at 72,000 gallons and on T-81 is set at 66,000 gallons.
Water maintained-in T-90 and T-91 is over and above that required by tech.
specs.
Section5.2
/
- 1.
Item a. l: Palisades _operates with the LPSI motor operated vaives norn;ia.lly closed.
In addition, online leak detection is provided between the primary coolant system check valve and the LPSI header (6") check valve.
- Thus failure of both the primary system check and the LPSI check during normal operation with the PCS at pressure is not a significant safety concern.
_ li't?.ilure of a.LPSI check during high press_ure s~fety injection system
-bp~ratibh ~oiioiiirti k:*smaii brei3.k LOCA o~"--Main *steam Line Break could cause over-pressure failure of the LPSI system and diversion to the auxiliary building of more than 25% of available HPSI flow.
Although this failure is easily mitigated by closing the HPSI motor operated valve to the affected injection path, t:ne design of the HPSI system is such that diversion of more than 25% of available HPSI flow is unaccep-table for LOCAs and steam line breaks.
In addition, the shutdown cooling system would not be available for long term cooling in such an event, although backup means of shutdown cooling do exist as described on page 20.
It should be noted that low pressure interlocks on the LPSI valves could have an adverse effect on the plant response in large LOCA situations.
The large LOCA is sensitive to the LPSI delivery time which could be further delayed as a result of the proposed interlocks.
Section 5.4
- 1.
Page 64, third and fourth paragraphs:
Palisades plant procedure EOP 10, "Control RoomEvacuation," describes the necessary steps to take the plant to cold shutdown using only instrumentation and con-trols located outside the control room.
Section 5.5
- 1.
Item 4:
Proposed fire protection system modifications will assure control air for the steam valves to the turbine driven auxiliary feedwater pump for at least two hours by dedicated air bottles (even assUming loss of all AC power).
These modifications will be implemented after NRC approval.
- 2.
Item 8:
i"Ianual actuation of the AFW system at the system level from the control room is currently provided at Palisades.
Simply starting the motor driven awaliary feedwater pump or opening one of the steam supply valves to the turbine driven pump will result in delivery of AFW to the steam generators.
No positioning of the auxiliary feedwater control valves is necessary with the valve flow controllers in their normal, automatic position.
.....L..-.
0 5
- 3.
Item 9:
AFW steam and feedwater lines were analyzed under IE Bulletin 79-14 and NUREG CR-1833, and found acceptable.
Qualification of the
.Pl!J!lPS.is being addressed as requested in Enclosure 2, Item 2 of NRC letter* dated.January 19,
- 1981 * ( *sEP Topic III-6 )'.
Appendix A
- 1.
Page A-4, second paragraph:
The Palisades Technical Specifications define cold shutdown as reactor coolant temperature less than 210° F.
- 2.
Page A-5, third paragraph:
More than 600,000 lb of water is normally stored in the Palisades Class I Condensate Storage Tank.
- 3.
Page A-6, fourth sentence:
PCS pressure must.be reduced to less than 265 psig (not 255 psig) before the SCS isolation valves can be opened.
Eighth sentence:
No plant procedure presently exists for entering containment to manually open the auxiliary spray valve if the plant
---*-.c'oriipressed air s*ysteni"is Uiiava*H'able.
~Should the. operator fail to perform this action, the PCS could be depressurized by manually opening a PORV.
- 4.
Page A-8, staff position #1:
Such procedures are only necessary for events in which the main condenser is not available after reactor trips.
- 5.
Table 1:
The initial secondary inventory is low by approximately 10,000 lbm.
The stored sensible heat of PCS metal is high considering the fact that the total PCS metal mass is less than 2,000,000 lb.
The stored sensible heat of PCS fluid is high since.the normal PCS liquid inventory (including pressurizer inventory) is less than 460,000 lbm.
The net result is that the staff's estimate of required water inventory appears to be conservative.
Technical specifications require 100,000 gallons of water in the condensate storage tank (T-2) and T-81.
Water in 'l'-90 and T-91 is in excess of tbis requirement.
The low level alarm on T-2 is currently set at 72,000 gallons and on T-81 at 66,000 gallons.