ML18047A520
| ML18047A520 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/11/1982 |
| From: | Johnson B CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML18047A521 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.E.1.1, TASK-TM NUDOCS 8208180012 | |
| Download: ML18047A520 (4) | |
Text
- - J consumers Power company General Offices: 1945 West Parnell Road, Jackson, Ml 49201 * (517) 788-0550 August 11, 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 PALISADES PLANT - AUXILIARY FEEDWATER SYSTEM MODIFICATION (ADDITIONAL INFOR1"1ATION)
Consumers Power Company letter dated November 2, 1981 provided an update to NUREG-0737, Item ILE.1.1 "Auxiliary Feedwater System Evaluation" which indicated our intention of converting the Palisades spare High Pressure Safety Injection (HPSI) pump to a third Auxiliary Feedwater (AFW) pump.
Following that submittal, a meeting was held with the NRC staff on December 1, 1981 at which time this proposed AFW modification was presented for discussion.
This meeting and then a telephone call on March 25, 1982 resulted in a NRC request for additional information.
The four identified areas in which additional information was needed are addressed by this letter and a~e as follows:
Additional Information Items and Responses ITEM
- 1.
Evaluation of AFW flow requirements for HPSI pump conversion.
RESPONSE
This evaluation was performed by our NSSS supplier, Combustion Engineering, and is provided as Attachment 1.
ITEM
- 2.
Control Schematics for the new system.
RESPONSE
The logic diagrams for the new system are provided as Attachment 2 which consists of discussion and diagrams provided to Consumers Power Company by Bechtel.
8208180012 820811 PDR ADOCK 05000255 p
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DMCrutchfield, Chief Palisades Plant
.AFW System Modification - Addt'l Info August 11, 1982 Additional Information Items and Responses (Continued)
ITEM 2
- 3.
Commit to using the new A~iliary Feedwater Pump (P8C) as the normal pump so the auxiliary feedwater system would meet the design guidelines of Branch Technical Position ASE 10-1.
BTP ASE 10-1 requires; "When considering a high energy line break, the system should be arranged as to assure the capability to supply.necessary emergency feedwater to the steam generators, despite the postulated rupture of any high energy section of the system, assuming a concurrent single active failure."
RESPONSE
A high energy line break in the present auxiliary feedwater pump room causing failure of both pumps in that room combined with the active failure of the new pump would cause a total loss of auxiliary feedwater.
By normally only using the new pump for feedwater, one does not have to assume a pipe break in the present auxiliary feedwater pump room because of Section B.2.e of BTP MEE 3-1 which says, "Through-wall cracks instead of breaks may be postulated in the piping of those fluid systems that qualify as a high-energy fluid systems for only short operational periods but qualify as moderate energy fluid systems for the major operational period."
Footnote 6 says that an operational period is considered short if the system is a high energy fluid system less than 2 percent of time, "However, systems such as auxiliary feedwater systems operated during PWR startup, hot standby, or shutdown qualify as high-energy fluid systems."
Committing to only using P8C for normal auxiliary feedwater while P8A and P8B are only used for emergency situations and Tech-Spec testing presents two problems.
First, plant availability may be reduced, depending on how the Tech-Specs are revised when the third pump becomes operational.
Second, in order to supply chemicals for chemistry control of the steam generator secondary side, an entirely new chemical addition system will have to be added, or modifications will have to be made to the one that already exists but is connected only to the present auxiliary feedwater pumps.
Consumers Power Company believes that committing to not using P8A and P8B for normal operation is unnecessary because the probability of a line break occurring concurrently with the failure of PBC, and a demand for auxiliary feedwater, to be very remote.
The reliability study done on the Palisades auxiliary feedwater system done prior to modifications (Reference 1) stated; "A system design change is needed to meet the high energy line break criteria of SRPl0.4.9.
- However, the cut set results reported in Section 4.2 indicates that ruptures or leaks in valves (and pipes) do not contribute significantly to system unavailability.
In the results reported in Section 4.2, pipe and valve ruptures generally contributed much less than 1% of the system unavailability for all four events analyzed."
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DMCrutchfield, Chief.
Palisad~s Plant AFW System Modification - Addt'l Info August 11, 1982 Additional Information Items and Responses (Continued)
RESPONSE
(Continued for ITEM 3)
Therefore, with the addition of the new auxiliary feedwater train, the contribution from a pipe break is even further reduced.
In conclusion, committing to using P8C as the normal auxiliary feedwater supply 3
would not measurably increase the reliability of the system but would cause expensive modifications and could possibly reduce plant availability.
Reference:
- 1.
Palisades Auxiliary Feedwater Reliability Study - Phase 2 dated October 1980 by Science Applications, Inc.
ITEM
- 4.
Endurance test on the new AFW pump.
RESPONSE
An endurance test on the new AFW pump is being planned and should be similar to the test previously run on the other AFW pumps in June of 1980.
Brian D Johnson Staff Licensing Engineer CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachments
C-E Power Systems Combustion Engineering. Inc.
1000 Prospect Hill Road Windsor. Connecticut 06095
.---'!!POWER
.......... SYSTEMS e ATTACHMENT 1 Tel. 203/688-1811 Telex: 99297 J~ll 2 2 1982 P-CE-6146 January 18, 1982 1~te Tc:
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I Consumers Power Company Palisades Plant Consumers Power Company 1945 Parnall Road Jackson, Michigan 49201 Attention:
Mr. A. D. Mulholland
Subject:
AFWS Modification - Phase 2
Attachment:
Evaluation of Auxiliary Feedwater Flow Requirements For High Pressure Safety Injection Pump Conversion Gentlemen:
As requested, the attached analysis of the Auxiliary Feedwater Flow Requirements for HPSI Pump Conversion is provided for review and submittal to the NRC.
WDM/RVA:jcp Attachment cc:
F. W. Buckman w/att.
D. J. VandeWalle w/att.
D. R. Hughes w/att.
H. J. Palmer w/att.
R. P. Margol w/att.
N. Hough w/att.
Very truly yours, w.n.~
W. D. Meinert Palisades Project Manager P. K. Smith w/att.
J. I. Dotson w/o att.
V. M. Suttles w/o att.
J. M. Fraser w/o att.
P. Sepcenko w/att.