ML18046A820
| ML18046A820 | |
| 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-06-07.A3, TASK-6-7.A3, TASK-RR NUDOCS 8107280483 | |
| Download: ML18046A820 (20) | |
Text
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consumers
- power company General Offices: 212 West Michigan; Avenue, Jackson, Michigan 49201 * (517) 788-0550 July 22,. 1981 Director, Nuclear Reactor Regulation Att Mr Dennis M Crutchfield, Chief Operating Reactors Branch No 5 US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - SEP TOPIC VI-7.A.3, ECCS ACTUATION SYSTEM By letters dated November 12, 1980 and May 19, 1981, the NRC transmitted its evaluation and SER, respectively, for Palisades SEP Topic VI-7.A.3. Consumers Power Company has completed a review of these doctiments and finds them gener-ally acceptable except as noted in the attached report.
As you will note in reviewing the attached report, we have reviewed this topic in considerable detail. Because the st.aff evaluation was very general in nature, and did not provide much detail in support of its conclusions, we found it necessary to thoroughly evaluate the entire topic in order to verify accuracy. To ensure that the record is complete, we have elected to docket the entire report rather than simply a brief summary.
It should also be noted that the staff evaluation is oriented toward ECCS only whereas the review criteria pertains to periodic testing of all ESF including overlap of sequential tests. We have, therefore, made our review broader than the staff's to more clearly address and document consistency with all review criteria.
Robert A Vincent S~aff Licensing Engineer CC Director, Region III, USNRC NRC Resident Inspector ~ Palisades
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1 ENCLOSURE PALISADES PLANT - SEP TOPIC VI-7.A.3 ECCS Actuation System I. SYNOPSIS OF THE.NRG TECHNICAL EVALUATION /
The NRC Technical Evaluation (TE) of the subject SEP Topic deals with the testability and operability of the Emergency Core Cooling System (ECCS) actuation system. Specifically, the TE reviewed the Plant design to
": .. assure that all ECCS components, including the pumps and valves, are included. in the component and system test, that the frequency and scope of the periodic testing are adequate, and that the test program meets the requirements of the current licensing criteria .... " The current licensing criteria utilized by the NRG.is listed below:
- 1. GDC 37 (Ref 1), entitled "Testing of Emergency Core Cooling System,"
requires that the ECCS be designed to permit appropriate periodic pressure and functional testing to assure the operability of the system as a whole and, under conditions as close to design as practi*
cal, to verify the performance of the full operational sequence that.
brings the system into operation, including operation of applicable portions of the protection system, the transfer between normal and emergency power sources, and the operation of th~ associated cooling water system.
- 2. Branch Technical Position ICSB 25 (Ref 2), entitled "Guidance for the Interpretation of GDC 37 for Testing and Operability of the Emergency Core Cooling System as a Whole," states that all ECCS pumps should be included in the system test.
- 3. Regulatory Guide 1.22 (Ref 3), entitled "Periodic Testing of the Protection System Actuation Functions," states in Section D.1.a that the periodic tests should duplicate as closely as practicable the performance that is required of the actuation devices in the event of an accident.
4 .. Standard Review Plan Section 7.3, Appendix A (Ref 4), entitled "Use of IEEE-Std-279 in the Review of ESFAS and Instrumentation and Controls of Essential Auxiliary Supporting Systems," states in Section 11.b that:
Periodic testing should duplicate, as closely as prattical, the integrated performance required from the. ESFAS, ESF. systems, and. their essentia-1 auxiliary supporting systems. If such a "system level" test can be performed only during shutdown, the testing done during power operation must be reviewed in detail.
Check that "overlapping" tests do, in fact, overlap from one test segment to another. For example, closing a circuit breaker with the manual breaker control switch may not be adequate to* test the ability of the ESFAS to close the breaker.
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2
- 5. Regulatory Guide 1-. 22 states in Section D. 4 that:
Where actuated equipment is not tested during reactor operation, it should be shown that:*
- a. There is no practicable system design that would permit operation of the actuated equipment without adversely affecting the safety or operability of the Plant;
- b. The probability that the protection system will fail to initiate the operation of the actuated equipment is, and can be main ..
tained, acceptably low without testing.the actuated equipment during reactor operation; and
- c. The actuated equipment can be routinely tested when the reactor is shut down.
In addition to the above criteria, the NRC provided.its reviewers with review guidelines as given below:
(1) Verify that the test conditions come as close as possible to the actual performance required by ECCS during accident mitigation (GDC 37-Item 3, ICSB-25, RG 1.22-D.1.a, SRP 7.3-Appendix A-11.b).
(2) Verify that the system test covers from end toend (sensor through actuated device). If partial tests are performed, verify that the overlapping tests indeed overlap from one test segment to another (GDC 37..,.Item 3, ICSB-25, SRP 7.3-Appendix A-11.b, RG 1.22-D.2).
(3}. Summarize the ECCS system surveillance testing interval as defined in the Plant's technical specifications.
As a result of the TE, the NRC concluded that the Palisades Plant complies with current licensing criteria. In addition, the NRC has concluded that the test frequencies specified in the Techni~al
- Specifications did not indicate any significant deviations from the Standard Technical Specifications. This conclusion is doc~ented in a May 19, 1981 letter from D M Crutchfield (USNRC) to D P Hoffman (Consumers Power Company).
II. DETAILED REVIEW OF THE.NRG TECHNICAL EVALUATION In an attempt to determine the degree of accuracy of the TE and the validity of its conclusions, the TE was reviewed. in detail. This review consisted of verifying the accuracy of statements documented in Section 4, "Systems Description" (where the ECCS is defined as the Safety Injection System being comprised of three subsystems: (1) the high-pressure safety injection system, (2) the low-pressure safety injection system, and (3) the safety injection tanks), and Section 5, "Evaluation and Conclusions" of the TE. Upon completion of the above review, it was possible to determine the validity of the TE conclusions documented in nu0781-0262a*46
Sections 5 (last paragraph) and 6. Since the NRC has performed an audit of the test frequencies specified in the Technical Specifications and has determined that no significant deviations exist, another review of test frequencies was not performad.
Section 4 of the TE is accurate for the most part. The statements made in this section are identical to those already published in the. FSAR. A review of the FSAR shows that the individual paragraphs of this section come from the following FSAR paragraphs:
TE Section *4 Corresponding Paragraph No FSAR Paragraph No 1 6.1.1 2 6.1.2.1 2 (1) 6.1.2.2.c 2 (2) 6.1.2~2.b 2 (3) 6.1.2.2.e Paragraph 2 of the TE, however, should have also included the safety injection recirculation actuation system (RAS) as part of the ECCS.
Paragraph 6.1.2.1 of the FSAR describes the role of the RAS during ECCS operation.
A review of Section 5 of the TE was also conducted on a paragraph-by-paragraph basis. The below table documents the review of Section 5 by itemizing each TE paragraph and providing comment as to whether the TE is accurate.
TABLE Review of Section 5 "Evaluation and Conclusions" of SEP Topic VI-7.A.3 "ECCS Actuation System" Technical Evaluation
.Section 5* Section 5 Paragraph No/ Paragraph Page No Comment Accurate?
1/9 Major portions of the ESF control ciictiits Yes can, and are, tested while the Plant is at power~ Procedure Q0-1 "Safety Injection" demonstrates the operability of the Safety Injection System (SIS) initiation circuitry by using the internal testing capability of the system. This procedure tests the performance of the SIS circuits during both a simulated SI with or without standby power available. This test is run quarterly with the reactor coolant system
- Refer to Section 5 of the subject SEP Technical Evaluation for the actual paragraph referenced.
nu078i-0262a-46
4 Section 5* . Section 5 Paragraph No/ Paragraph Page No Comment Accurate?
pressure greater than 1400 psia. Other monthly test procedures are also conducted at power:
/
MI-4, "Pressurizer Low-Pressure SIS Initiate and Pressurizer High-Level Alarm" MI-5, "Containment High-Pressure Initiation Ciicuits for RPS, SIS and CIS" More extensive circuit sequence and load testing, as well as RAS testing, is performed when the Plant is shut down.
These'procedures are listed below:
Q0.,.8,. "ESS Check Valve Operability Test .and High-Pressure Safety Injection Flow Indica-tor Verification" R0~8,. "Engineered Safeguards System" R0-12, "CHP Spray System Tests" R0-13, "Normal Shutdown Sequence Tests" RI-14, "SIRW Tank Level Switch Interlocks Tests" Procedure R0-8 is conducted at every refueling to determine the operability of the Emergency Power System, Engineered Safeguards System and the manual safety injection feature of the engineered safe-guards controls. This is determined by verifying correct sequencing and loading of safeguards equipment (including all ECCS pumps) when an SIS actuation is simulated (by manually tipping the pressurizer low-pressure indicator and alarm units) coinci-dent with an actual loss of normal and standby power. The manual SIS feature is verified by alarm indication after the SIS push button is depressed. This test dupli-cates, as close as practical, the inte-grated performance required from the Engineered Safety Features Actuation System
- Refer to Section 5 of the subject SEP Technical Evaluation for the actual paragraph referenced.
nu0781-0262a-46
5 Section 5* Sectian 5 Paragraph No/ Paragraph Page No Comment Accurate?
(ESFAS), the Engineered Safety Features (ESF) and thei.r auxiliary support systems.
SIS circuit design is such that each redundant circuit (or channel) is.tested separately so that the correct operation of each circuit can be identified. Although R0-8 requires a total loss of Plant voltage (both emergency buses) and a complete SIS actuation (both channels), the manual SIS initiate is conducted on a channel-by-channel basis. Q0-1, however, fully utilizes the test circuit design in that each channel of SIS is tested separately.
Procedure R0-13 is performed during re-fueling to demonstrate the operability of the normal shutdown sequence through testing the equipment starting circuits and contact closure times. In this test, the "normal shutdown sequencer" test switch is used to simulate the loss of standby voltage without SIS. Upon actuating this spring return switch to the test positiori (and holding the switch in that position),
the sequencer relays will energize. The sequencer contact timing is then verified.
Releasing the switch concludes the test as the sequencer relays are not sealed in (see Drawing E209-2). Each channel is individually tested.
Procedure RI-14 requires that the RAS be tested by lifting the safety-related SIRW tank level switch probes above the water level to effect an auto RAS actuation.
Upon actuation, the control room recircula-tion initiation alarm is verified. This alarm is wired to a contact on one of the SIRW tank low-level relays. Upon RAS initiation, these relays energize and, among other things, cause the alarm. This procedure tests all possible 2/4 level switch combinations.
- Refer to Section 5 of the subject SEP Technical Evaluation for the actual paragraph referenced.
nu0781-0262a-46
6 Section 5* Section 5 Paragraph No/ Paragraph Page No Comment Accurate?
Quarterly procedure, Q0-2 "Recirculation Actuation System" (which, like RI-14, is conducted during shutdown) also tests the RAS. In this test, however, a test switch is used to simulate the RAS initiation condition (low SIRW tank level). Upon placing this switch in the "test" position, the SIRW tank low-level relays are ener-gized to effect RAS initiation. Actual component response verifications are made in this procedure. All required component response verifications are made except for the closure of the low-pressure safety injection pump's minimum recirculation valve. The component response verifications include:
- 1. Low-pressure safety injection pumps trip,
- 2. Containment sump isolation valves open,
- 3. SIRW tank isolation valves close,
- 4. Component cooling water heat exchanger service water valves open, and
- 5. Component cooling water heat exchanger cooling water valves open.
2/9 Two mode selector switches are provided in Yes the SIS and DBA test circuitry. The first switch allows the operator to simulate an SI with or without standby power available (see Dwg E210-l). The second switch allows the operator to simulate a loss of standby power with or without an SI (see Dwg E209-2). Procedure Q0-1 calls for the use of the first switch and, as previously described, Procedure R0-13 calls for the use of the second switch.
A momentary type push button is provided to simulate the SIS in each of the redundant control channels. Procedure Q0-1 calls for the use of this SIS test push button as a
- Refer to Section 5 of the subject SEP Technical Evaluation for the actual paragraph referenced.
nu0781-0262a-46
7 s*ection 5* Section 5 Paragraph No/ Paragraph Page No Comment Accurate?
means of system initiation. Q0-1 utilizes the left push button for left channel testing and the right push button for right channel testing. As described in Q0-1, the test is terminated upon releasing the push button. Drawings E209-1 and E210-l reveal that these push buttons do not result in "sealing-in" the actuated components.
Therefore, releasing this push button will automatically reset the SIS or DBA se-quencer relays.
3/9 Testing in the "without standby power" mode Yes does not initiate load shedding since load shedding is purely a function of actual voltages on the emergency buses. Each component that features load shed input circuitry, utilizes a load shed "a" contact in its trip circuits. This "a" contact closes to provide component trip whenever
_the emergency bus de-energizes (see Dwg E259).
After a test, all of the solenoid valves (with the exception of the containment sump drain valves) will reset automatically.
Other initiated equipment such as motor-.
operated valves and pump motors will not automatically reset. Letter: D P Hoffman to J G Keppler, 6/23/80, provides a list of all ESFAS actuated equipment and whether or not this equipment automatically resets upon SIS reset.
4/10 Procedure Q0-1 simulates the SIS by requir- Yes ing that the momentary test push buttons be depressed. Upon depressing the button, the test requires that the operation verifies proper load response. An alternate method of initiating the SIS is by tripping two-out-of-four pressurizer low-pressure de-vices in the SIS initiating circuit matrix (see Dwg E206-1). Procedure R0-8 actually calls for this method of SIS initiation.
Procedure Q0-1 simulates the loss of standby power and sequences the loads.
- Refer to Section 5 of the subject SEP Technical Evaluation for the actual paragraph referenced.
nu0781-0262a-46
- 8 Section "'5* Section 5 Paragraph No/ Paragraph Page No Comment Accurate?
Procedure R0-8 verifies bus sheddirig and actual sequence loading of components by causing an actual loss of standby power.
5/10 As previously described, the procedures Yes, with used to test the Safety Injection System the excep-are Q0-1 and R0-8. The acceptance t ion of criteria for each of these procedures pump shut-is given below: off head.
- a. "The equipment which is designated in the tables has actuated to the condition shown in the Test Operation column ... "
- b. "The equipment which is designated in the tables has been actuated by the sequencers."
R0~8
- a. "The testwill be considered satisfac-tory if it is verified that both diesels start, load sheds and the OBA sequencers start and load all the required Engineered Safeguards Equipment."
- b. "OBA sequencer timing is considered satisfactory if set point tolerances listed on Attachment 2 are satisfied."
- c. "Operation of Engineered Safeguards Equipment is considered satisfactory if all equipment performs its required action as specified inAttachment 1."
- d. "Manual SIS initiation is considered satisfactory if the alarms required in Sections 5.13 and 5.16 are verified.
Neither Q0-1 nor R0-8, however, requires that the pumps reach rated shutoff head at minimum recirculation flow and operate for
- Refer to Section 5 of the subject SEP Technical Evaluation for the actual paragraph referenced.
nu0781-0262a-46
9*
Section 5* Section 5 Paragraph No/ Paragraph Page No Comment* Accurate?
at least 15 minutes. Shutoff head at mini-mum recirculation flow is tested for the ECCS pumps during the monthly inservice inspection pump tests. During these tests, it is required that the pumps operate for at least 15 minutes. These tests are:
M0-19 for the containment spray pumps, M0-22 for the high-pressure injection pumps, and M0-23 for the low-pressure safety injection pumps.
6/10 The high-pressure safety injection pumps, Yes, with low-pressure safety injection pumps (shut- the excep-down cooling pumps) and the containment tion of spray pumps are tested monthly. According daily checks to test Procedures M0-19, M0-22 and M0-23, of the the method of starting each pump is alter- contain-nated between the control room and the ment high-local breaker eV~ry month. pressure switches.
In accordance with Procedures D/W0-1 "Operators' Daily/Weekly/Biweekly Items" and SH0-1 "Operators' Shift Items" all of the safety injection and containment spray initiation instrumentation that features control room indication (such as, pressur-izer pressure channels and containment high radiation channels) are checked either daily or shiftly. The safety-related containment high-pressure c*ircuits do not feature control room indication and are, therefore, tested monthly along with the other SIS and containment spray initiation circuitry. The procedures listed below are used to perform these tests.
MI-4, "pressurizer low-pressure SIS initiate and pressurizer high-lev~l alarms" MI-5, "containment high-pressure initiation circuits for RPS, SIS and CIS"
- Refer to Section 5 of the subject SEP Technical Evaluation for the actual paragraph referenced.
nu0781-0262a-46
10
.;Section 5* Section 5 Paragraph No/ Paragraph Page No Comment Accurate?
MI-6, "area monitors, operational check" As previously mentioned, Procedure Q0-1 (which is performed quarterly) tests the operation of the starting circuits and verifies that the active components (ie, pumps and valves) operate satisfactorily upon receipt of the SIS signal.
1110* Procedure SH0-1 requires that the Safety' Yes Injection Tank level and pressure be checked shiftly during power operation.
Procedure Q0-8 is used to test the two series check valves between the safety injection tank and the reactor coolant system. According to the procedures, the.
piessure control system is used to test the valves and monitor the test pressures between the valves. Q0-8 tests the check valve nearest the tank by opening the leakage control valve to allow the check valve to pass tank water whenever the pressure downstream of the tank check valve decreases below the tank pressure.
8/11 During the SI tank check valve test de- Yes scribed above, Procedure Q0-8 requires that the test line flowmeter be used to verify flow. Drawing M203 (attached) shows that tank pressure and level instrumentation could also be used to monitor flow rate out of the tank.
To test the check valve nearest the reactor.
coolant system, Procedure Q0-8 requires that the charging pumps be aligned to the redundant high-pressure safety injection pump line to pump water through the valve.
9/11 The TE description of the method employed No to test the check valve nearest to the reactor coolant system is incorrect. The following description provides a brief synopsis of the method employed in Procedure Q0-8 (refer to Dwg M203):
- Refer to Section 5 of the subject SEP Technical Evaluation for the actual paragraph referenced.
nu0781-0262a-46
11 Section '5* *Section 5 Paragraph No/ Paragraph Page No Comment Accurate?
If the primary system pressure is not already greater than the pressure on the SI tank side of the check valve, the tank's motor-operated discharge isolation valve is closed. The charging system is aligne~ to direct charging pump discharge flow into the high-pressure safety injection header through the test line f lowmeter and on through the check valve under test. During the flow period, the equilibrium pressure (on the SI tank side of check valve) is monitored by the pressure contr.ol system.
Tµe che.ck valve will open whenever the pressure on the SI tank side of the check valve becomes greater than the reactor coolant system pressure. At this point, flow through the check valve is verified by the in-line test flowmeter.
The last portion of this review deals with the subject of overlap .. Test overlap is necessary to ensure that the complete engineered safeguards function is verified in the event that segments of the complete function are tested individually. Although the Technical Evaluation does not make mention of this subject, Standard Review Plan Section 7.3, Appendix A, Section llb (see Section I *Of this review), requires that tests be reviewed to ensure that test overlap does exist.
- At Palisades, the complete engineered safety function (which consists of the Safety Injection System, the containment isolation system and the emergency power system) is tested in segments. Upon reviewing these tests, it has been determined that these tests have sufficient overlap to allow a verification of the operability of the complete engineered safety function. The following paragraphs describe the overlap that presently exists.
The SIS is initiated by either pressurizer low-pressure or containment high-pressure conditions. During refueling, Procedure RI-3, "High Pressurizer Pressure Channels Calibration," requires that a t:est pressure be input to the safety-related pressurizer pressure sensors (transmit-ters). Upon reaching the proper set point by varying the pressure input, the appropriate pressurizer pressure indicator and alarm (PPIA) unit actuation is verified.* Procedure RI-7, "Low-Pressure SIS Initiation Logic," overlaps with RI-3 in that RI-7 requires that a signal generator, connected into the various pressurizer pressure current loops (upstream of the PPIAs), be used to activate various combinations of the four PPIA units (one per channel) to produce the two-out-of-four pressurizer
- Refer to Section 5 of the subject SEP Technical Evaluation for the actual paragraph referenced.
nu0781-0262a-46
12 low-pressure trip inputs to the *SIS. The SIS initiation is verified by the SIS trip alarms which are energized by the SIS output relays.
Monthly Procedure MI-4, "Pressurizer Low-Pressure SIS Initiate and Pressurizer High-Level Alarm," also tests these circuits in a method similar to Procedure RI-7. In MI-4, however, the 2/4 combinations are not verified. MI-4 simply verifies one channel at a time.
The containment high-pressure (CHP) input to the SIS is verified in a manner similar to that used in Procedure RI-3. Procedure R0-12, "CHP Spray System Tests," requires that a test pressure be inserted into the safety-related CHP sensors (pressure switches). Upon reaching the proper set point, the actuation of the SIS is verified using the SIS trip alarms; These alarms are energized by the SIS output relays.
The SIS is tested quarterly per Section Q0-1, "Safety Injection System,"
to demonstrate the operability of the SIS circuitry by using the internal testing capability of the system. This test overlaps Tests RI-7 and R0-12 in that, during the Q0-1 test, the internal test circuits are used to simulate a safety injection condition with and without standby power available which energizes the SIS output relays. Upon initiation, all of the ESF loads are verified to resporid appropriately.
During refueling, Procedure R0-8, "Engineered Safeguards System,"
requires that an actual loss of voltage occurs in the emergency buses concurrent with a trip of the PPIA units to effect a full design basis accident. Proper sequencing and timing of the sequenced loads are verified. Also verified is the appropriate response of the other ESF loads. This test overlaps Tests RI-7, R0-12 and Q0-1.
The containment isolation function is verified in one "system test." - As previously mentioned, Procedure R0-12 requires that a test pressure be inserted into the _CHP sensors (pressure switches). In addition to verifying SIS initation, the procedure also requires that containment isolation (CI) actuation be verified. According to the procedure; the verification is to be made by logging the response of at least one containment isolation valve for each of the CHP relays that energize upon receipt of the CHP condition as sensed by the pressure switches (sensors). Although overlap is not a problem with this test, the test does not verify the proper response of all of the containment isolation valves to the CHP condition.
In addition, the containment high radiation input to containment isola*
tion is verified. Procedures RR-10, R0-11 and MR-6 are used. RR-10, "Area Monitor Calibration," utilizes a known external radiation source to verify the proper safety-related area monitor output. During the conduct of R0-11, "Containment High Radiation Test," the set points of the safety-related area monitors are adjusted downward using a comparator po-tentiometer to cause a containment isolation initiation from all possible combinations of the four area monitors. The response of all of the containment isolation valves is verified.
Valid verification of trip action is provided in Procedure R0-11. The area monitor trip circuitry features a comparator circuit which produces nu0781-0262a-46
13 an output 'trip S'ignal whenever the relative difference of the comparator inputs (ie, incoming detector signal and set point signal) is reduced to zero. Therefore, a valid verification of comparator output trip signal can be made by either inputting a high radiation source at the detector or by adjusting the trip set point down using the comparator potenti-ometer. In either case, the relative difference between the two comparator inputs is eliminated. Upon verifying the trip, the procedure requires that the set po{nt by returned to the original setting as logged in the control room's Radiation Monitor's Set Point Logbook.
Procedure MR-6, "Area Monitor Operational Check," requires that the Radiation Monitor's Set Point Logbook area monitor trip set point be checked monthly. According to the procedure, the trip set point is to be verified as within a specified set point range or a set point adjustment can be made. This adjustment is made using the comparator potentiometer.
As a result of the above description, it can be said that sufficient overlap exists to provide a valid verification of complete containment high radiation to containment isolation channel operability.
Proper overlap exists in the recirculation actuation testing program ..
Test RI-14 requires that the safety-related SIRW tank level switch probes be lifted which energize the SIRW tank low-level relay as procedurally verified by a control room alarm which is energized by these relays.
Procedure Q0-2 utilizes a test switch to energize the SIRW tank low-level relays to actuate the required loads. Load response is then procedurally verified.
SUMMARY
The Palisades Plant testability of the operation and performance of the ECCS actuation system (as defined in the TE) conforms to the licensing criteria described in Section 2 of the TE. Two exceptions to the above, however, exist. The containment high-pressure test does not include all of the containment isolation valves in its verification requirements. In addition, the recirculation actuation tests do not verify the response of the low-pressure safety injection pump mini recirculation valve.
nu0781-0262a-46
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