ML18046B167
| ML18046B167 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/23/1981 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| TASK-05-10.B, TASK-05-11.B, TASK-08-03, TASK-5-10.B, TASK-5-11.B, TASK-8-3, TASK-RR LSO5-81-12-074, LSO5-81-12-74, NUDOCS 8112280306 | |
| Download: ML18046B167 (10) | |
Text
Docket No. 50-255 LS05 l 2-074 Mr. David P. Hoffman December 23, 1981 Nuclear Licensing Administrator Consumers Power Company 194-5 W Parnall Road Jackson, Michigan 49201
Dear Mr. Hoffman:
SUBJECT:
PALISADES - SEP TOPICS V-10.B, RHR SYSTEM RELIABILITY, V-11.B, RHR INTERLOCICREQUIREMENTS AND VII-3, SYSTEMS REQUIRED FOR SAFE SHUTDOWN (SAFE SHUTDOHN SYSTEMS REPORT)
As preparation for the integrated assessment, the staff has re-evaluated some of the open items from the topic reviews to determine whether they can be resolved'within the topic rather than being carried into the integrated assessment.
For topics c:overed by the safe shutdown systems review, (V-10.B, V-11.B, and VII-3), the staff consid~rs the following items to be closed out as discussed below.
The deviation concerning independent, diverse interlocks for the shut-down cooling system (SCS) suction valves which prevent the valves from opening unless primary coolant system (PCS} pressure is below SCS design pressure is considered acceptable. The key lock switches and administrative controls, along with the pressure interlock on the inboard valves provide adequate assurance that the SCS will not be inadvertently exposed to high
- PCS pressure.
For operation v1:i'th_ fir.e protection water as auxiliary feedwater, the staff had recommended that operating procedures be revised to direct cooldown to SCS initiation conditions within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, and then proceeding to cold shutdown expeditiously.
The proposed increase in the Technical Specifica-"
tion minimum volume in the condensate storage tank will decrease the 1 i kel i 7 hood of prolonged use of the fire protection water. Therefore, the staff..,,
does not consider the proposed procedural changes to be of sufficient
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safety significance for inclusion in the integrated assessment.
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USGPO: 19~1-335-960 -
David Enclosed are revised pages of the safe shutdown systems report which should be substituted into the evaluation transmitted on October 27, 1981.
Concurrently, the staff is revising the safety evaluation for V-11.B (previously dated June 2, 1981) to be consistent with the above.
The remaining staff positions from the safe shutdown evaluation are being considered in the integrated assessment:
- 1.
Modification to the technical specifications to require enabling of the overpressure protection system prior to initiating SCS.
- 2.
Operating procedures for a shutdown and cooldown using the systems identified in the minimum systems list (Section 3.1 of the evalua-tion}.
- 3.
Provision of suitable interlocks on the low pressure safety injec-tion {_LPSI) discharge vctlves to prevent opening until pressure is below LPSI design pressure or demonstration that the consequences of failure of a LPSI check valve are acceptable.
- 4.
Maintenance of at least 107,000 gallons of onsite water and development of procedures to achieve SCS initiation temperature and pres*sure within seven hours after reactor trip to permit a safe shutdown and cooldown with loss of offsite power.
- 5.
Maintenance of 100,000 gallons of the 107,000 gallons of onsite stored water in the seismic category I condensate storage tank, Enclosure; As* stated cc w/enclosure:
See next page Sincerely, Dennis M. Crutchfield, Chief Operating Reactors Branch No. 5 Division of Licensing OFFICE*..** ~~P.B..=.D.krl4J1 '.... ~.;[~........ ~.L.~.;.QL...... --;2}~~~... _Qg}~,v~....... ~.P1~~:.Qh...........................
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UNITED STATES NUCLEAR REGULATORY COMMISSION Docket No. 50-255 LS05 12-074 Mr. David P. Hoffman WASHINGTON, D. C. 20555 December 23, 1981 Nuclear Licensing Administrator Consumers Power Company 1945 W Parnall Road Jackson, Michigan 49201
Dear Mr. Hoffman:
- e.
SUBJECT:
PALISADES - SEP TOPICS v.. 10.B, RHR SYSTEM RELIABILITY, V-11. B, RHR INTERLOCK REQUIREMENTS AND VII-3, SYSTEMS REQUIRED FOR SAFE SHUTDOWN (SAFE SHUTDOWN SYSTEMS REPORT)
As preparation for the integrated assessment, the staff has re... evaluated some of the open items from the topic reviews to determine whether they can be resolved within the topic ~ather than being carried irito the integrated assessment.
For topics covered by the safe shutdown systems review, (V-10.B, v.. 11.B, and VII-3), the staff considers the following items to be closed out as discussed below.
The deviation concerning independent, diverse interlocks for the shut-down cooling system (SCS) suction valves which prevent the valves from*
opening unless primary coolant system (PCS) pressure js below SCS design pressure is considered acceptable.
The key lock switches and administrative controls, along with the pressure interlock on the inboard valves provide adequate assurance that the SCS will not be inadvertently exposed to high PCS pressure.
For operation with fire protection water as auxiliary feedwater, the s:taff had recommended that operating procedures be revised to direct cooldown to SCS i niti ati on condi ti ens w-ithin 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, and then proceeding to cold shutdown expeditiously.
The proposed increase in the Technical Specifica~
ti on minimum volume in the condensate storage tank wi 11 decrease th.e l i keli....
hood of prolonged use of the fire protection water. Therefore, the staff does not consider the proposed procedural changes to be of sufficient safety significance for incluston in the integrated assessment,
David Enclosed are revised pages of the safe shutdown systems report which should be substituted into the evaluation transmitted on October 27, 1981... Concurrently, the staff is revising the safety evaluation for.
V-11.B (previously dated June 2, 1981) to be consistent ~ith the above.
The remaining staff positions from the safe shutdown evaluation are
_being considered in the integrated assessment:
- 1.
Modification to the technical specifications to require enabling of the overpressure protection system prior to initiating SCS.
- 2.
- Operating procedures for a shutdown and cooldown using the systems identified in the minimum systems list (.Section 3.1 of the evalua-tion}.
- 3.
Provision of suitable interlocks on the low pressure safety injec~
tion (LPSI) discharge valves to prevent opening until pressure is *
- below LPSI design pressure or demonstration that the consequences
- of failure of *a *LPSI check valve are acceptable,
- 4.
Maintenance of at least 107,000 gallons of onsite water and.
development of procedures* to achieve SCS initiation temperature and pres*sure within seven hours after reactor trip to permit a
- safe shutdown and cool down wtth loss of offs i te.. power.*
- 5.
Maintenance of 100,000 gallons of the 107,000 gallons of onsite stored water tn the seismic cat.egory I condensate storage tank.
Enclosur~:
As stated cc w/enclosure; See next P.age Sincerely, t1~*1/ "?//~
r Dennis M. Crutchfield, Chief Operating Reactors Branch No. 5 Division of Licensing
Mr. David P. Hoffman r
cc M. I. Miller, Esquire Isham, Lincoln & Beale Suite 4200 One First* National Plaza Chicago, Illinois 60670 Mr. Paul A. Perry, Secretary Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Judd L. Bacon, Esquire Consumers Power Company 212 West Michigan Avenue 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 Dri.ve Midland, Michigan 48640 Kalamazoo Public Library 315 South Rose Street Kalamazoo, Michigan 49006 Township Supervisor Covert Township Route_ l, 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.
Pl ant Manager Covert, Michigan 49043 e.
U. S. Environmental Protection Agency
- Federal Activities Branch Region V Office*
ATTN:
Regional lladiation Representative 230 South Dearborn Street Chicago, Illinots 60604 Charles Bechhoefer, Esq., Chairman Atomic Safety and Licensing Board Panel
- u. s. Nuclear Regulatory Corrmission 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
' \\...
ENCLOSURE SYSTEMATIC EVALUATION PROGRAM TOPICS V-10.B, V-11.B, VII-3 PALISADES REVISED PAGES FOR SYSTEMS REPORT DECEMBER 1981
e..
50 The PCS suction supply to the LPSI pumps is from the hot leg of loop 2 through motor-operated valves M0-3015 and M0-3016 in series. The SCS uses the LPSI pumps for coolant circulation.
SCS return flow is via all four SI lines to the PCS cold legs.
The permissiye interlock for the SCS suction yalves is described in Reference 5, and it prevents opening M0-3015
- and M0-3016 unless PCS pressure is below 265 psig.
The pressure signal is generated by PS-0104 on the pressurizer for input to the interlock on both suction valves.
The two motor-operated valves also have administratively controlled* key-locked switches in the control room.
By procedure, the SCS system. ts not placed into operation until pressure is below 270 psia and the.
. overpressure system is operable.. The single interlock is a deviation from the independent diverse interlock provision of BTP RSB 5-1.
There.are. no interlocks whith automatically shu~ the SCS suction or discharge valves* on increasing PCS pressure.
The SCS suction and discharge isolation valves fail
."as is 11 on loss of power and have position indication in the control room.
On the discharge side of the SCS, protection from PCS pressure is provided by two check valves and the motor-operated LPSI valve in ~ach of the four SI lines.
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.
The motor-operated valves open upon receipt of an SI signal.
Based on the above description, the SCS deviations from these BTP provisions:
Palisades ~Safe Shutdown Revised 12/81
e*.
\\l \\.r 51 \\
- 1.
The suction valves do not have independent diverse interlocks to prevent opening the valves until PCS pressure is below SCS design pressure.
2.. The motor-operated valves in the discharge lines are not interlocked to prevent opening on an SI signal until PCS pressure is below SCS design pressure.
- 3.
The isolation valves have no interlock to close them when PCS pressure
. increases* above the SCS design pressure.
The deviation for lack of automatic suction valve closure on increasing PCS pressure is acceptable since in addition to the administrative and proce*du_ral controls on these valves, an alarm is provided at 375 psig to warn the operator that PCS pressure is increasing towards SCS design pressure whenever the Over-pressure Protection System is.enabled.
Upon receipt of an a:larm, the control room operator would be able to terminate the pressure increase or to perform
- the required procedural steps to isolate the SCS.
(See the following dis-cussion of BTP provision C. 1, 11 Pressure Relief Requirements").
The deviatio~ concerning the independent interlocks on the suction valves to prevent opening until PCS pressure is below SCS design pressure is accept-able since the keylock switches and administrative controls in addition to the existtng interlock provi"de assurance that a single failure or single operator error will not result in overpressurization of the SCS.
Palisades - Safe Shutdown Re vi sed 12/ 81 *
- e.
65 a*
The licensee will be required to incorporate plant Technical Specifications to require enabling the overpressure protection system whenever SCS cooling fs in progress.
- b, The licensee wi11 be required to provide suitable interlocks on the LPSI discharge valves to prevent the valves from opening unless pressure is below LPSI design pressure or demonstrate that the consequences of failure of a LPSI check valve are acceptable.
5.3 Tooic V-11.B RHR Interlock Requirements The safety objective of this topic is identical to that of Topic V-11.-A.
The staff conclusion regarding the Palisades SCS valve interlocks, as discussed in Section 5.2, is that adequate interlocks exist after implenentation of the indicated staff conclusions.
5.4 Topic VII-3 Systems Required For Safe Shutdown The Safety objectives of this topic are:
- 1.
To assure the design adequacy of the safe shutdown system to (a) initiate automatically the operation of appropriate systems, Pqlisades - Sqfe Shutdown Revtsed 12/81
A-9 Based on the staff's evaluation of sa~e shutdown water requirements at Palisades, we have concluded that the plant systems identified in the SEP Safe Shutdown Report would permit a plant cooldown in accordance with the intent of BTP.RSB 5-1 requirements if the following staff positions are implemented:
- 1. The licensee should maintain (by Technical Soecification) at
- least 107,000 gallons of on-site water and dev.elop procedures to achieve SCS initiation temperature and pressure within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> after reactor trip to permit a safe shutdown and cooldown with loss of offsite power using on-site water.
- 2.
Of the 107,000 gallons of water, discussed in item l above, 100,000 gallons should be maintained in the seismic category I CST.
Palisades - Safe Shutdown Revised 12/81