ML18047A341
| ML18047A341 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/02/1982 |
| From: | Johnson B CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8206040241 | |
| Download: ML18047A341 (2) | |
Text
consumers Power company General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-0550 June 2, 1982 Dennis M Crutchfield, Chief Operating Reactors Branch No 5 Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 -
LICENSE DPR-20 PALISADES PLANT -
TECHNICAL SPECIFICATION CLARIFICATION FOR CONTAINMENT ISOLATION VALVE TESTING Consumers Power Company has determined a possible area of question regarding Palisades Plant Technical Specification interpretation concerning containment integrity when performing tests related to containment isolation valves.
The purpose of this letter is to document clarification of the appropriate Technical Specification sections based on discussion with Mr T Wambach of the NRC Staff.
In defining containment integrity, Palisades Technical Specification (TS) 1. 4 requires all automatic containment isolation valves to be operable or locked closed.
Palisades Technical Specification 3.6 requires containment integrity to be maintained unless the reactor is in cold shutdown, and has no provision for being in a degraded mode of operation.
The specifications referred to above present a problem in the scheduling and performance of certain tests related to containment isolation valves.
For example, Q0-11 (Containment Isolation Check Valve Test Procedure) verifies the ability of check valves to seat by applying a reverse differential pressure across the valves.
The method of performing the test is to close the inboard isolation valve, open the test valves between the inboard and outboard (check) valve and then pressurizing between them.
During the period the test valves are opened, the outboard isolation valve (check valve) is bypassed with respect to its containment integrity function and must be considered inoperable regardless of its position.
Local leak tests are also performed in essentially the same manner as described above, and are occasionally required to be performed during plant operation.
Logically, there is no reason the testing described above should not be performed during plant operation, since containment integrity is, in effect, maintained (although not by definition) by one closed valve.
Section 3.6.4.c of the CE Standard Technical Specifications (STS) permits containment isolation valves to be inoperable provided the affected penetration is isolated by deactivating at least one automatic valve in the closed position within
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PDR ADOCK 05000255 P
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DMCrutchfield, Chief Palisades Plant Tech Spec Clarification for Containment Isolation Valve Testing June 2, 1982 four hours.
By applying the STS to this situation, and because TS 6.9.2b(2) allows entry into a degraded mode permitted by an Limiting Condition of Operation (LCO) in order to perform a required surveillance, the matter appears to be resolvable.
Another surveillance (monthly boron sample of safety injection tanks), which is required to be performed during plant operation, requires opening manual containment isolation valves in order to obtain a sample.
Palisades Technical Specification 1. 4 stipulates that all nonautomatic containment isolation valves shall be closed in order to have containment integrity.
On the other hand, STS Section 3.6.4.C allows manual containment isolation valves to be inoperable (implying they may be opened) provided at least one valve is closed within four hours.
Consumers Power Company's clarification of the Palisades Technical Specifications to permit unrestricted testing of containment isolation valves and sampling of Safety Injection Tanks is based on the CE Standard Technical Specifi~ations and has been discussed with Mr T Wambach of the NRC Staff and is intended for use until appropriate changes are made to section 3.6 of the Palisades Technical Specifications.
The two points to this clarification are as follows:
- 1.
Allow unrestricted testing of containment isolation valves by permiting containment isolation valves to be inoperable provided the affected penetration is isolated by deactivating at least one automatic valve in the closed position within four hours.
- 2.
Allow unrestricted boron sampling of safety injection tanks by permiting manual containment isolation valves to be opened provided the affected penetration is isolated by at least one closed manual valve within four hours.
Brian D Johnson
'Senior Licensing Engineer CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades