ML18047A408

Responds to NRC 810929 Ltr Re Functionability of Pressurizer Safety Valves & Power Operated Relief Valves,Per NUREG-0737, Item II.D.1.A.Final Rept to Be Submitted by 821231

ML18047A408
Person / Time
Site:	Palisades
Issue date:	06/30/1982
From:	Johnson B CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Crutchfield D Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.D.1, TASK-TM NUDOCS 8207060177
Download: ML18047A408 (3)

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consumers Power company General Offices: 1945 West Parnell Road, Jackson, Ml 49201 * (517) 788-0550 June 30, 1982 Dennis M.Crutchfield, Chief Operating Reactors Branch No 5 Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - L!CENSE DPR PALISADES PLANT - RESPONSE TO NRC LETTER DATED SEPTEMBER 29, 1981 -

SUBJECT NUREG-0737 ITEM II.D.l.A The purpose of this letter is to provide the Consumers Power Company response to the NRC letter dated September 29, 1981 which requested by July 1, 1982 a submittal that addresses the functionability of the pressurizer safety valves and power operated relief valves (PORVs) that are installed in the Palisades system. Item II.D.l.A of NUREG-0737 required that utilities operating and/or constructing Pressurized Water Reactor (PWR) power plants provide evidence, supported by test, of safety and relief valve functionability. In response to these requirements, the Electric Power Research Institute (EPRI) implemented a generic test program on behalf of the PWR utilities. Consumers Power Company has been a participant in the EPRI program. The NRC Generic Letter 81-36 dated September 19, 1981, contains a schedule for the submittal of test results and the submittal of plant-specific reports. In accordance with this schedule, results of the EPRI program, summarized in various EPRI reports, were forwarded to the NRC on April 1, 1982, in parallel with distribution to the participating utilities.

In order to facilitate an expeditious evaluation of the test data, the utilities operating and constructing Combustion Engineering (C-E) designed plants have, 'through the C-E Owners Group, requested that C-E implement a program to evaluate and apply the EPRI test results. The C-E Owners Group program was subsequently initiated in April, 1982, and is currently in progress. Consumers Power Company is a participant in this program.

The approach being applied by the C-E Owners Group is to show that particular EPRI tests were directly representative of plant-specific safety and relief valve models and valve installations, and that acceptable valve operation was demonstrated. The portion of the program related to PORVs has already been completed. Accordingly, C-E report CEN-213, entitled "Summary Report on the Operability of Power Operated Relief Valves in C-E Designed Plants,"

is being forwarded separately to the NRC by Mr Kenneth P Baskin, Chairman of the C-E Owners Group. Consumers Power Company considers report CEN-213

.--- 820 7060111 020630 _ ~or;~

PDR ADOCK. 05000255 PDR p .

DMCrutchfield, Chief Palisades Plant Response to 9/29/81 NRC Letter -

NUREG-0737, Item II.D.l.A 2

June 30, 1982 to provide the required information on PORV operability for Palisades.

Although (in the high pressure mode) Palisades does not presently take credit for the PORVs, and operates with the block valves closed. The evaluation of the. PORVs and their associated piping includes both high pressure and low pressure conditions.

With regard to the evaluation of safety valves, our review of the EPRI tests has determined that the valves and installat~ons used at Palisades were represented in the EPRI program and the test conditions enveloped the range of fluid conditions recommended by NUREG-0737. The valve discharge for Palisades is limited to steam conditions, and the valves are installed on short inlet pipes extending from the pressurizer. This type of arrange-ment and the steam condition has been shown in the EPRI program to be the most optimum for the valves to perform their function. Although there is no safety concern, future valve adjustments may be beneficial to assure optimal performance. Currently, detailed plant-specific evaluation and application of the EPRI data is being performed as part of the Owners Gro.up pro gr am. In addition, input from the valve manufacturers is being requested. That information is expec~ed to be received during the third quarter of 1982, and will then be incorporated into the C-E evaluation. If valve adjustments are necessary, they will be identified in the C-E evaluation based on performance demonstrated by the EPRI tests.

The results will be presented in a C-E Owners Group report that is scheduled for completion in December 1982. Since Consumers Power Company is a participant in the program, the operability of safety valves in the Palisades systems will be addressed by this report.

In addition, Palisades has a contract with E.D.S. Nuclear, Inc. to investi-gate the adequacy of our safety and relief valve discharge piping and support system. This investigation is being conducted along EPRI suggested guide-lines making use of EPRI approved RELAP5/MOD1 computer code. A final report from E.D.S. is expected on or before November 1, 1982.

Although, as stated previously, Palisades does not use the block valves in the pressurizer relief valve system while the system is in the high pressure mode, plans are being made to thoroughly investigate the operation of the block valves by comparing the EPRI block valve test results and consulting with the valve manufacturer. *It is expected that this investigation will be completed by November 1, 1982.

DMCrutchfield, Chief Palisades Plant Response to 9/29/81 NRC Letter -

3 NUREG-0737 Item II.D.l.A June 30, 1982 Currently, our intent is to provide you with the final report, which will serve as our final submittal, by December 3l, 1982.

Brian D Johnson Senior Licensing Engineer CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades