ML18046A971
| ML18046A971 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/16/1981 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| TASK-06-10.A, TASK-6-10.A, TASK-RR LSO5-8110-027, LSO5-8110-27, NUDOCS 8110210137 | |
| Download: ML18046A971 (4) | |
Text
Docket No. 50-255 LS05-8liJlQ;.. 027
~..,.....
Mr. David P. Hoffman October 16,-1981 Nuclear L1cens1ng Administrator Consumers Power Company 1935 W Parna11 Road Jackson, M1ch1gan 49201
Dear Mr. Hoffman:
SUBJECTz SEP TOPIC VI-10.A, TESTING OF REACTOR TRIP SYSTEM AND ENGINEERED SAFETY FEATURES, INCLUDING RESPONSE TIME TESTING, SAFETY EVALUATION FOR PALISADES The enclosed revised staff safety.evaluation is based on a contractor document that has been made available to you previously and has been ri'!Odified to cite- ~he current standard and reflect the comments in your
- letter of July 2~', 1981. This evaluation supports the findings of the staff safety evaluation of Topic VI-10.A and proposes modifications to the Technical Specifications and some equipment to implement a response
--~
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time testing program.
The need to ac~ij~:py implement.these changes will be detennfoed during the integrated safety assessment. This topic assessment may be revised 1n the future if your facility design is changed or ff NRC.criteria relating to this topic are modified before the integrated assessment is c~mpleted.
. Sincerely,
- Dennis M. Crutchfield, Chief Operating Reactors Branch No. 5 Division of Licensing GP' 5.s 1/1
Enclosure:
As stated
().S<4. \\&tie (o'f) cc w/enclosure:
See next page a1102D100c1~70~bb8~~~
POR A PD~
j;,NFfC fORM 318 (10-80) NRCM 0240.
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-r: m:,,L,,,~Js OFFICIAL RECORD COPY.
USGPO: 1981-33&-960
.. e Mr. David P. Hoffman r
cc M._ I. Miller, Esquire __.-_
Isham, Lincoln & Beale Suite 4200 -
- One First Natfonal Plaza Chicago, Illinois* 60670:
Mr~ Paul A. Perry, Secretary Consumers Power Company 212 West Michigan Avenue:
-Jackson, Michiga~ 49201' J-udd i... s*acon, Esquire Consumers Power Company 212 West Michigan Ayenue Jackson, Michigan 49201 Myron M. Cherry, Esquire Suite 4501 One IBM Plaza Chicago, Illinois 60611 Ms. Mary P. Sinclair Great Lakes Energy Alliance 5711 Summerset Drive
-Midland, Michigan 48640 Kalamazoo Public Library 315 South Rose Street Kalamazoo, Michigan 49006 Township Supervisor Covert Township Route 1, -Box 10 Van Buren County, Michigan 49043 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 U. S. Environmental Protection
--. _- Agency -* * -*
Federal Activitie~ Branch ~
- *Region V Office-*
- *_ATTN:
Regional ~adiation Representative 230 South Dearborn Street Chitago, Illinois 60604 -
Charle*s -Bechhoefer, Esq., Ch-airman Atomic Safety and Licensing Boar9 Panel
- U~ S. Nuclear ReguJatory Corrmissfon
- Washington, D. c. -* 20555- - _. __
Dr. George C. Anderson _.
Department of Oceanography
/
University of Washington Seattle, Washington 98195 Dr. M. Stanley Livingston 1005 Calle Largo*-
Santa Fe, New Mexico 87501 Resident Inspector c/o U. S. NRC Palisades Plant Route 2, P. o. Box 155 Covert, Michigan 49043
/
e SYSTEMATIC EVALUATION PROGRAM TOPIC VI-10.A.
PALISADES TOPIC:
VI-10.A, TESTING OF REACTOR TRIP SYSTEM AND ENGINEERED SAFETY FEATURES, INCLUDING RESPONSE TIME TESTING I.
INTRODUCTION The purpose of this Topic is to review the reactor trip system (RTS) and engineered safety features (ESF) test program for verification of RTS and ESF operability on a periodic basis and to verify RTS and ESF response time in order to assure the operability of the RTS and ESF.
Respon~e
- times shoul~ not exceed those assumed in the plant ac~ident analyses *.
-Atcordingly, the ~est program of the RTS and ESF was reviewed in accord-ance with the Standard Review Plan, including applicable Branch Technical P6sitions.
- II.
REVIEW CRITERIA
. ~ ':
'*.The review d~i'tefi~ ar~* pres~~ted in Section 2-of IG&G'Rep~rt llB3~4170,
-"Testing of Reactor Trip Systei:n and Engineered Safety Features; :Including
.Response Time Testing".* However, due to changes made to the applicable Standard, Regulatory Guide 1.118 references should be replaced by a refer-ence to 1EEE Std. 338-1977.
III.
RELATED SAFETY TOPICS AND INTERFACES Topic VI-7.A.3-discusses the question of testing protection systems under conditions as close to design condition as practical. There are no topics
. that are dependent on the P.resent topic information for their completion.
}V.
REVIEW GUIDELINES Review guidelines are presented in Section 3 of Report 1183-4170. These guidelines should also reference-.IEEE 338 in lieu of the Regulatory Guide.
V.
EVALUATION.
Palisades complies with the cuf~ent 11cens1ng criteria, except for Section 6.3.4 of IEEE Std. 338-1977 (response time test) and overlapping tests of the high rate-of-change of power trip. Response time testing is a significant aspect of testing emergency equipment because it is the only way to verify that the equipment will perform its safety function within the required time (the time assumed in the safety *analyses).
\\
1
"'.iltl
,._ VI.
CONCLUSION
- lt :is the staff's position that the design of sy~teiris wh1ch 'are. required
_for safety shall include provisions for periodic veri_fication that the
- minimum performance. of instruments and control is not l~ss than that which was assumed in the safety analyses.
The bases for this position
-are General Design Criterion 21, Section 3.9* of IEEE Std._ 279-1971, and IEEE Std. *338-1977.. Therefore, the licens~~ would have to implement
.a 'program for response time testing of all* reactor 'protection systems (including engineered safety features systems such as containment is9la"".
tion) to meet these criteria.
Overlapping tests of anticipatory trips such as the high* rate-of-change
- of power trip are not necessary because no safety.funct~on--is invp,.ved. -
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