ML18046B254
| ML18046B254 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/04/1982 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| RTR-REGGD-01.045, RTR-REGGD-1.045, TASK-05-05, TASK-05-10.A, TASK-5-5, TASK-RR LSO5-82-02-030, LSO5-82-2-30, NUDOCS 8202080228 | |
| Download: ML18046B254 (7) | |
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Docket No. 50-255 LS05 02-030 Mr. David P. Hoffman Nuclear Licensing Administrator Consumers Power Company 1945 W. Parna 11 Road Jackson, Michigan 4 9201
Dear Mr. Hoffman:
February 4, 1 982
SUBJECT:
PALISADES - SEP TOPIC V-5, REACTOR COOLANT PRESSURE BOUNDARY LEAKAGE DETECTION Enclos:ed is a copy of our final evaluation of SEP Topic V-5 for Palisades.
This assessment compares your facilityr; as described in Docket No. 50-255, wHh the criteria currently used by the regulatory staff for licensing new facilities. This revised evaluation factors in the information contained in the March 1 0, 1981 and July 16, 1981 letters from the NRC to you, your October 7, 1981 letter on this sU'bject, pertinent information contained in SEP Topic V-10.A and avaUable 10 CFR 50, Appendix I submittals for Pali-sades.
This evaluation concludes that the Palisades reactor coolant pressure boun-dar-y leakage detection systems do not presently conform to the recommen-dations of ~egulatory Guide 1.45 and presents the modifications needed to establish compliance.
The necessity for implementation of the modifications will be considered during the integrated safety assessment. This assess-ment may be revised in the future if your facility design is changed or if NRC criteria relating to this subject are modified before the integrated r./
assessment is completed.
~ £o 8202080229 820204 PDR ADOCK 05000255 P
Enclosure:
As stated cc w/enclosure:
See next page
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SEPB OFFICE......................
SURNAME..... ~.~.9.¥.1.~.:.RL
'!/ I /82 DATE.........................
Sincerely, Dennis M. Crutchfield, Chief Operating Reactors Branch No.
Division of Licensing
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5 T, M.c~6 NRC FORM 318 (10-80) NRCM 0240 OFFICIAL RECORD COPY USGPO: 1981-335-960 I
SYSTEMATIC EVALUATION PROGRAM TOPIC V-5 PALISADES TOPIC:
V-5 Reactor Coolant Pr.essure Boundary (RCPB) Leakage Detection INTRODUCTION I.
The safety objective of Topic V-5 is to determine the -reliability and sensitivity of the leak detection systems which monitor the reactor coolant pressure boundary to identify primary system leaks at an early stage before failures occur.
- I I.
REVIEW CRITERIA The acceptance criteria for the detection of leakage from the reactor coolant pressure boundary is stated in the General Design Criteria of Appendix A, l O CFR Part 50.. _ Cri.terion 30, 11 Qual ity of Reactor Coolant Pressure Boundary 11, requites that~eans shall be provided for detecting and, to the extent practical, identifying the location of the sources of leakage in the reactor cool a-nt pressure boundary.
III.
REVIEW GUIDELINES The acceptance criteria are described in the Nuclear Regulatory Commis-sion Standard Review Plan Section 5.2.5, "Reactor Coolant Pressure Boundary Leakage Detection 11
- The areas of the Safety Analysis Report and Technical Specifications are reviewed to es ta-bl i sh that information submitted by the licensee is in compliance with Regulatory Guide 1.45, 11 Reactor Cool ant Pressure Boundary Leakage Detection Systems 1.'.
IV.
EVALUATION Safety Topic V-5 was evaluated in this review for compliance of the information submitted by the licensee with Regulatory Guide 1.45, 11 Reac-tor Coolant Pressure Boundary Leakage Detection Systems 11 rhe informa*
tion in the Safety Analysis Report, Technical Specifications, the March 10, 1981 and July 16, 1981 letters from the NRC to Consumers Power Co.
regarding SEP Topic V-5 for Big Rock Point and Palisades, the April 21, 1979 letter from the NRC to Consumers Power Co. regarding SEP Topic V-10.A, the October 7, 1981 CPCo. letter to NRC providing comments on Topic V-5, and the available 10 CFR 50, Appendix I review information for Palisades was reviewed.
Regulatory Guide 1.45 requires that at least three separate detection systems be installed in a nuclear power plant to detect unidentified leakage from the reactor coolant pressure boundary to the primary con-.
tainment of one gallon per minute within one hour.
Leakage from identi-fied sources must be isolated so that the flow rates may be monitored separately from unidentified leakage.
The detection systems should be capable of performing their functions following certain seismic events and capable of being checked in the control room.
Of the three separate
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leak detection methods required, two of, the methods should be (1) sump level and flow monitoring and (2) airborne particulate radioactivity monitoring.
The third method may be either monitoring of condensate flow rate from air coolers or monitoring of airborne gaseous radioac-tivity. Other detection methods, such as humidity, temperature and pressure, should be considered to be alarms of indirect indication of leakage to the containment.
In addition, provisions should be made to monitor systems interfacing with the reactor coolant pressure boundary for signs of intersystem leakage through methods such as radioactivity and water level or flow monitors.
Plant incorporated systems and their corresponding features are tabulated in Enclosure 1.
Detailed guidance for the leakage detection system is contained in Regulatory Guide 1.45.
Based upon our review of the referenced documents and the summaries presented in Enclosure 1, we have determined:
(1)
The systems employed for the detection of leakage from the reac-tor coolant pressure boundary to the containment do not meet the requirements of Regulatory Guide 1.45. Specifically, the airborne particulate radioactivity monitor required by the Guide is not present.
The sensitivity of the sump level monitor is far from that indicated in Regulatory Guide 1.45.
In addition, the sensi-tivity of the gaseous radiation monitor is adequate at 1%.failed*
fuel, but it is not clear that this is the*case with lower amounts of failed fuel. Also, only the airborne gaseous radioactivity monitoring system is testable during normal operation.
The con-densate flow rate from the air coolers monitoring system and other additional *detection systems are not seismically qualified to function following earthquakes up.to the DBE level, as detailed in the acceptance criteria of SRP 5.25.
(See Table l of Enclo-sure l for further details.)
(2)
The Palisades Technical Specifications do not impose requirements concerning*the operability of* the leakage detection systems to monitor leakage to the primary containment, as recommended by Regulatory Guide 1.45.
(3)
Provisions are made to monitor reactor coolant in-leakage to those systems listed in Table 2 of Enclosure 1. However, from the review of the referenced information it is not clear that this table in-cludes all systems which interface with the' reactor coolant pressure boundary.
In addition, except for the control rod drive mechanism.
seal leakoff, the identified systems are not testable during no*rmal operation and, except for the component cooling water system surge tank level, the identified systems are not seismically qualified to function following earthquakes up to the QBE level.
(4)
Palisades FSAR Amendment. 15 (Question 4.3) indicates that eves Makeup Flowrate is included as a Plant Incorporated System for leak detection, however, information regarding this method is not given such that Table 3 of Enclosure 1 is incomplete.
(5)
Information concerning the use of reactor coolant inventory balances, as indicated in Table 3 of Enclosure l, for RCPB leakage detection is incomplete, therefore, its contribution to overall system effec*
tiveness cannot be determined.
V.
CONCLUSIONS Our review indicated that the systems employed at Palisades to measure reactor coolant pressure boundary leakage do not meet the recommendations given in Regulatory Guide 1.45. Specifically, our review concludes that:
(1)
The type* of leakage detection systems incorporated for measurement of leakage from the reactor coolant pressure boundary to the contain-ment are not in conformance with Regulatory Guide 1.45 criteria.
{2) A section should be added to the Palisades Technical Specifications concerning operability of the reactor coolant pressure boundary to the containment leakage detection systems.
Standard Technical Specification 3/4.4.6 and the corresponc:ling surveillance requireme-nts should be used as guidance for the development of this section for the leakage detection systems:required as a result of the integrated safety assessment.
(3)
Information concerning the leakage detection systems for the detection of inter-system reactor cool ant press_ure boundary leakage and the eves Makeup Flowrate is incomplete.
Therefore, we cannot determine the extent to which Regulatory Guide 1.45 is met.
(4)
Information concerning the use of the-primary coolant system inventory balance leak rate sensitivity and time required to achieve sensitivity is incomplete.
Therefore, we cannot determine the contribution of this technique to the overall leak detection sensitivity.
The necessity for any leakage detection system modifications will be considered durin~ the integrated safety assessment.
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.Table 1 :
RCPB to Con.tainment System
- 1) Sump Level Mon.i tori!ng (Inventory)
- 2)
Sump Pump*Actuations Monitoring'" (Time Meters)
- 3) Airborne Particulate Radioactivitv MonitorinQ
- 4) Airborne Gaseous Radioactivity Monitoring
- 5) Condensated Flow Rate from Air Coclers (P ry! 1805~. 1812, PT/P.IA.18l4~ 1815) 6 Containment Atmosphere Pressure MonitorinQ
- 7) tH I 1812, 13 14, 1 5}
ontainr ent Atmosphere Humidit** MonitorinQ
- 8) tTl 18L., 13A 14, 15) ontaini1ent tmosphere Tempera :ure MonitorinQ
- 9) Accoust :c Emissions 1 0) Moistur! Sensitive Tape
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REACTOB COOLANT PRESSURE BOUNDARY LEAKAGE DETECTION SYSTEMS Regulatory Guide 1.45 Requirements Plant: PALISADES r
Time Req'd Earthquake For Control Room..
Leak Rate to Achieve Which*function Indication For Incorporated Sensitivity Sensitivity Is Assured Al arms &**Indicators 0:23 g H Alarm at approx Yes
- 25 gpm 1 hr.
- 0. 13 g v Yes 3
11 in sump No Water is drained by gr. vity through two NC remotely operated Isolation valves operati r action is requ red to drain sump.
No O. 3.g H Yes
- .03 gpm
- 45 min.
Yes 0.14 g v Level Fl ow Rate Greater than Yes Switch 20 anm See FSAR Yes Amend. 17 Yes Yes
- 2.5 gpm 1 hr.
Yes 0.217 g H Yes Unknown Unknown Yes.
0.067 g v Yes, PORVs and safety Unknown none Yes
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No Document-ation Ref-erence FSAR Amend.
15, Question 4 ~
FSAR Amend.
15, Question 4 1 FSAR Section 6.3.2.1 FSAR Amend.
17, Question LI. n FSAR Amend.
15, Question 4.3 CPCo Letter 12/19/80 Testable ~*-
During N1>r mal Oper1t on No Yes
.~*-
No -*-
No No No No
and Drai.n Tank Level Detectors
.. Yes Alarm at 1500 psig; Volume 35 in3 1 i quid f o ",*.... Yes 15, Question No 1
n11ti:>r c:a:>l ni pc;_al arm 4 1
- 2) Safety
,~alve and PORV Seat Leakage
.Yes
- Small, FSAR Amend, via TemJerature Monitors Valve Unknown Yes 15 4juestion No.
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- Based u~on dividing the total "leakage stated in the referenced documentation by 60 min. to derive the constant rate necessary during a'*l hr. period.
- Minim11m1senc;itivity and time based upon an assumption of 1% failed fuel.
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REACTOR COOLANT PRESSU~E BOUNDARY LEAKAGE DETECTION SYSTEMS Regulatory Guide 1.45 Requirements Plant: PALISADES Intersys1;_em Leakage Methods to Time Req'd Earthquake For Control Room Measure RCPB Leak Rate to Achiev~
Which*funct1on Indication For Systems~i~lhich Interface w/ RCPB In-Leakage Sensi ti vi ty Sensitivity Is Assured Al arms &**Indicators
- 1)
Seco11dary System (RIA-0631)
Air Ej_ector
< 5 gpm Yes
- Rad.. Monitor
'2)
Blowdown Rad.
Secondary System (RIA-2320)
Monitor
< 5 gpm Yes
- 3)
Component Cooling Water System
(:RIA-091 5)
Rad. Monitor v*es Surge Tank 0.487 g H
- 4)
Component Cooling Water System Unknown Yes (L:IA-0917)
Level Seal Leak-off
- 5)
Control Rod Drive Mechanisms Line Thermocou le <<l Yes gpm
- 6)
- 7)
- See FSAR S ection 11, Tab e 11-6 for these and other installed' Process radiat on monitors.
- 8)
- 9)
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- 0)
- 1)
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- 2)
Document-ation Ref-erence
,..-sAI< Amend.
15, Question 4 1 FSAR Am.end.
15, Question
- 4. 3" Test ible Duri mal 19 Nor-Jperation Yes*
Yes*
3/6/70 AEC SIR Sec~ 3.10, ard Yes*
4/21179 NRC I tr.
to CPCo re :SI P Top V-10.A,4/2l/i 9 NRC o CPCo re: SI P Top V-10.A.
FSAR Amend.
15, Question 4.3 a...* **
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j~t REACTOB COOLANT PRESSUijE BOUNDARY LEAKAGE DETECTION SYSTEMS Regulatory Gutde 1.45 Requirements
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!Ii*.RCS Inv:ntor,. Balance Ii/},..
Leak Rate Se**g Correspondin.
Time Require*
Ac hi eve SE~ns **
itiv~ty to
- '.vity
< l gpm
- Norma 1 *Im en
- r;1 Check
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Instrumentat on Required with Corresponding Location:
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l EarthquakE~ F.. r Which Instrumentation Ha.rdware Functioning Is Assured:
Testable Our**ng Nonnal Operation:
Documentatio<**;
Reference:
FSAR Amend. 15, Question 4.3 PALISADES I
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