ML18052A410
| ML18052A410 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/30/1986 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 8605060215 | |
| Download: ML18052A410 (32) | |
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consumers Power POW ERi Nii NllCHlliAN'S PROliRESS General Offices:
1945 West Parnell Road, Jackson, Ml 49201 * (517) 788'.1636 April 30, 1986
- Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
Kenneth W Berry Director Nuclear Licensing RESPONSE TO NRC INTERIM REPORT, CONFORMANCE.TO REGULATORY GUIDE 1.97 By a letter dat~d June 24, 1985 the NRC provided an interim report, prepared by EG&G Idaho, Inc., that reviewed Consumers Power Company submittals dated April 14, 1983 and September 13, 1983 regarding conformance of the Palisades Plant to the provisions of Regulatory Guide 1.97.
The letter noted that adequate justification had not been provided for some of the exceptions taken by Consumers Power Company to the provisions of Regulatory Guide 1.97.
The letter categorized these unjustified exceptions as 18 open items and requested that Consumers Power Company provide a response to those open items within 90 days.
L Subsequently, during discussions with your Staff and by a letter dated September 3, 1985, entitled "Response to NRC Request for Additional Information Regarding Conformance to Regulatory Guide 1.97", Consumers Power Company requested a delay until April 30, 1986 to respond to the interim report.
As justification, Consumers Power Company stated that the individuals who would be providing the response to the interim report were currently dedicated to completing other tasks required by Supplement 1 to NUREG-0737 and that providing a response to the interim report by the date requested in the interim report could result in delays in meeting those other commitments.
The attachment to this letter provides Consumers Power Companys response to the open items of the interim report.
For each item identified as requiring
- further justification in the interim report, information is provided to show that the current design meets the criteria of Regulatory Guide 1.97 or, justification is provided for the deviation from the criteria or, a commitment to meet the criteria of Regulatory Guide 1.97 is made.
86050b'C>215 860430 u
~DR ':/~DpCK 0500~5~5 OC0486-0016S-NL01
Director, Nuclear Reactor Regulation Palisades Plant Response to NRC Interim Report, Conformance to Regulatory Guide 1.97
--ApriL 30, 1986 2
Supplement 1 to NUREG-0737, Section 6.2, required each licensee to submit a report describing how it meets the requirements of Regulatory Guide 1.97 and supply supporting justification or alternatives for deviations from the guidance of Regulatory Guide 1.97.
Consumers Power Company submitted the required report entitled "Supplement 1 to NUREG-0737, Milestone Activity -
Regulatory Guide 1.97 Interim Report of Deviations" on September 13, 1983.
That letter provided a detailed list of each variable identified by R.G. 1.97, rev. 3 and the associated Palisades Plant instrument along with the guidelines the instrument met and justification for deviation from the requirements of R.G. 1.97, rev. 3.
In addition, that letter provided a list of unresolved discrepancies identified during the review of Palisa4es instrumentation against the guidelines of R.G. 1.97, rev. 3.
By a letter dated June 24, 1985 entitled "Supplement 1 to NUREG-0737, Section 6.2, Conformance to Regulatory Guide 1.97", the NRC concluded that Consumers Power Company had provided an explicit commitment to conformance*to Regulatory Guide 1.97 with the exception of items that we had identified as deviations from the requirements of R.G. 1.97. 'Included with that letter was an interim report prepared by EG&G Idaho, Inc.* The interim report indicated that while some of the exceptions taken by Consumers Power Company to R.G. 1.97 rev. 3 appeared acceptable certain other exceptions had not been adequately justified.* The attachment to this letter provides Consumers Power Company's response to each item identified in the interim report as requiring additional justification.
Thus, this letter and Consumers Power Company's letter dated September 13, 1983, taken together, fulfills the commitment made by Consumers Power Company in its letter. dated April 22, 1985 to submit, by Janua.ry 1987, a report, and an implementation plan and schedule, describing how the requirements of section.6. 2 (Regulatory Guide 1. 97 - Application to Emergency Response Facilities) of Supplement 1 to NUREG-0737 have been or will be met *.
Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment OC0486-0016S-NL01
/.,
OC0486-0016S-NL01 ATTACHMENT 1 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255.
RESPONSE TO NRC INTERIM REPORT CONFORMANCE TO REGULATORY GUIDE 1.97 APRIL 30, 1986 28 PAGES 3
I.
Background
ATTACHMENT 1 RESPONSE TO NRC INTERIM REPORT -
CONFORMANCE TO REGULATORY GUIDE 1.97 On December 17, 1982, NRC issued Generic Letter 82-33 (Reference 1) to all licensees.
In that letter, the NRC required that all licensees of operating reactors and holders of construction permits provide an evaluation of the conformance of their plants to Regulatory Guide 1.97 Rev 2 (Reference 2).
Consumers Power Company letter dated September 13, 1983 (Reference 3) provided the required evaluation for the Palisades Plant.
This evaluation was performed against the requirements of Regulatory Guide 1.97, Rev 3 (Reference 4) which was issued subsequent to Generic Letter 82-33.
NRC letter dated June 24, 1985 (Reference 5) provided an interim report prepared by EG&G Idaho, which addressed conformance to Regulatory Guide 1.97 at the Palisades Plant.
This letter requested that open items identified in the Conclusions section of the EG&G report be addressed, and that other comments regarding incorrect assumptions or commitments, which were beyond the intent of our previous responses, be identified.
II.
Discussion The following provides Consumers Power Company's response to each of the open items identified section 4 (Conclusions) of the interim report (Reference 5) on conformance to Regulatory Guide 1.97 at the Palisades Plant.
The numbering of each item in this report is consistent with the numbering of items in the interim report Conclusion section.
The section number in parenthesis refers to the section of the interim report which provides additional discussion of the item.
MI0386-0897A-TC01-NL04
~
Palisades Plant Response to NRC Interim Report Conformance to Regulatory Guide 1.97 April 30, 1986 NRC Position 2
- 1.
Environmental qualification requirement deviation - environmental qualification should be addressed in accordance with 10CFRS0.49 for the 29 (sic) identified variables (Section 3.3.1).
CPCo Response The environmental qualification criteria outlined in Regulatory Guide 1.97 have been superseded by 10CFRS0.49, "Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants", for Regulatory Guide 1.97 Categories 1 and 2.
Compliance with 10CFRS0.49 is, therefore, considered adequate to meet the environmental qualifica-tion requirements of Regulatory Guide 1.97.
By a letter dated January 31, 1985, the NRC issued a Safety Evaluation (SE) entitled "Environmental Qualification of Electric Equipment Impor-tant to Safety" which addressed the Palisades Plant's compliance to the requirements of 10CFRS0.49.
That SE stated that although the staff had not completed its review for conformance to Regulatory Guide 1.97; "The staff finds the licensee's approach to identifying equipment within the scope of paragraph (b)(3) of 10CFRS0.49 acceptable since it is in accordance with the requirements of that paragraph."
Appendix A of the interim report identified 30 variables for which environmental qualification had not been addressed.
Within the instru-mentation loop for these variables, the sensors and/or transmitters are the only instrument loop components which could potentially be located in harsh environments.
Other loop components such as indicators and power supplies are located in mild environments and, thus, are not subject to the provisions of 10CFRS0.49.
The environmental qualifica-tion status of each of the 30 variables listed in Appendix A of the interim report is discussed below.
MI0386-0897A-TC01-NL04 Palisades Plant Response to NRC Interim Report Conformance to Regulatory Guide April 30, 1986 A.
Neutron Flux 3
1.97 Indication of neutron flux covering the required range is provided by wide-range logarithmic channels NI-003 and NI-004.
The fission chambers and preamplifiers for these channels are located in the containment which is a harsh environment.
Other components of the instrument loop are located in mild environments.
The existing fission chambers and preamplifiers located in contain-ment are not environmentally and seismically qualified.
We are currently evaluating alternatives for replacement of components located in containment with qualified components.
This evaluation is considering such items as required range and interface require-.
ments with other systems such as the reactor protection system, and the operator information needs identified by the upgraded Emergency Operating Procedures (EOP) and the results of the Detailed Control Room Design Review (DCRDR).
Due to the long lead times necessary to engineer and procure this type of system, replacement of the nuclear instrumentation is scheduled for the second refueling outage from now.
This outage is currently scheduled for late 1988.
If, however, as a result of our evaluation, Consumers Power Company determines that environmentally qualified equipment is not required, we will notify the NRC and provide the appropriate justification for not qualifying this equipment.
B.
Primary Coolant System (PCS) Cold Leg Water Temperature Cold leg Resistance Temperature Detectors (RTD's) located in containment were upgraded with environmentally qualified components during the 1985 *refueling outage.
Other components of the cold leg temperature instrument loop are located in a mild environment and, thus, are not subject to the provisions of 10CFRS0.49.
MI0386-0897A-TC01-NL04 Palisades Plant Response to NRC Interim Report Conformance to Regulatory Guide 1.97 April 30, 1986 C.
PCS Hot Leg Water Temperature 4
Hot leg Resistance Temperature Detectors (RTD's) located in con-tainment were upgraded with environmentally qualified components during the 1985 refueling outage.
Other components of the hot leg temperature instrument loop are located in a mild environment and, thus, are not subject to the provisions of 10CFR50.49.
D.
PCS Pressure Pressurizer pressure transmitters located in containment were upgraded with environmentally qualified components during the 1985 refueling outage.
Other components of the pressurizer pressure instrument loop are located in a mild environment and, thus, are not subject to the provisions of 10CFR50.49.
E.
Containment Sump Water Level (Narrow Range)
Narrow range sump water level transmitters located in a harsh environment were upgraded with environmentally qualified components during the 1983 refueling outage.
Other components of the sump level instrument loop are located in a mild environment and, thus, are not subject to the provisions of 10CFR50.49.
F.
Containment Isolation Valve Position Containment isolation valves are located in both harsh and mild environments.
Isolation valve position switches for those valves located in harsh environments were upgraded to meet 10CFR50.49 requirements during the 1985 refueling outage.
Isolation valve position switches located in mild environments are not subject to the provisions of 10CFRS0.49.
MI0386-0897A-TC01-NL04
Attadunent 1 Palisades Plant Response to NRC Interim Report Conformance to Regulatory Guide 1.97 April 30, 1986
- d. *Residual Heat Removal System Flow 5
At Palisades, this function is performed by the sh.utdown cooling system (SDC).
Components required to monitor SDC flow are located in mild environments and, thus, are not subject to the provisions of 10CFRS0.49.
H.
RHR Heat Exchanger Outlet Temperature One major objective following any accident is to place the shutdown cooling system (SDC) in operation to provide for long-term core cooling.
With the shutdown cooling system in operation, the temperature which most closely represents cold leg temperature is the SDC heat exchanger outlet temperature.
The SDC heat exchanger outlet temperature element (RTD) is located in a portion of the auxiliary building designated as a harsh environment.
However, temperature and radiation levels are only slightly elevated at this location during design basis events.
For this reason, it is expected that the existing temperature element would continue to perform its function in the post-accident envi-ronment.
Nevertheless, this temperature element will be evaluated to determine if it can survive the postulated post accident service conditions at its current location.
This evaluation will be completed by September 1986. If the analysis shows that the exist-ing temperature element cannot meet environmental qualification requirements, it will be replaced with an environmentally qualified temperature element by the end of the next refueling outage cur-rently scheduled for mid-1987.
Our evaluation is also considering the operator information needs as identified by the upgraded EOPs and the results of the DCRDR.
If the results of this portion of our evaluation indicates that environmentallly qualified equipment is not required we will notify the NRC and provide the appropriate justification for not.
qualifying this equipment.
MI0386-0897A-TCOl~NL04 Palisades Plant Response to NRC Interim Report Conformance to Regulatory Guide 1.97 April 30, 1986 6
The remaining portions of the SDC heat exchanger outlet temperature instrument loop are located in mild environments and, thus, are not subject to the provisions of 10CFRS0.49.
I.
Accumulator Tank Level and Pressure The safety injection (SI) tanks are passive devices whose function is to reflood the reactor core following the blowdown phase of a large break Loss of Coolant Accident (LOCA).
The level and pres-sure instrumentation is provided for monitoring during normal operation to assure that the tanks contain a sufficient volume of pressurized borated water to perform their function if required.
For postulated accident events, which result in rapid PCS depres-surization to a point at which the SI tanks discharge their con-tents, the tank level and pressure quickly go to zero and, thus, indication of these parameters would no longer be required.
For other events which result in slowly decreasing PCS pressure, the containment environment would not be as severe as that occurring during a large break LOCA.
It is expected that the existing pressure and level transmitters would continue to function.
Even if random failures of the SI tank level and pressure instrumenta-tion should occur, there are no operator actions required during post-accident conditions which require knowledge of SI tank level and pressure.
Therefore, based on the above, CPCo does not consid-er that environmental qualification of SI tank level and pressure is required.
J.
Accumulation Isolation Valve Position Power to the SI tank isolation valves is locked out during normal operations to prevent inadvertent isolation of the SI tank from the primary coolant system (PCS).
For pos~ulated events, which result in rapid PCS depressurization to a point at which the SI tanks discharge their contents, there is no need to close the SI tanks' isolation valve.
For events which result in a ~lowly decreasing HI0386-0897A-TC01-NL04 Palisades Plant Response to NRC Interim Report Conformance to Regulatory Guide April 30, 1986 7
- 1. 97 primary system pressure, the containment environment would not be expected to be as severe as that resulting from a rapid PCS depres-surization.
For these less severe events, it is expected that both the SI tanks' isolation valves and vent valves' position indication would function properly to indicate isolation and/or venting of the tank; Therefore, based on the above, CPCo considers that qualification of the SI tank isolation valve position indication is not required.
K.
Boric Acid Charging Flow In the Palisades design, boric acid charging flow and makeup flow are one and the same.
For a discussion of this variable see Item Y.
L.
Flow in High Pressure Safety Injection (HPSI) System The HPSI flow transmitters are located inside containment and have not been environmentally qualified.
Because these instruments provide the most direct method to monitor and control HPSI flow during postulated accident conditions, the flow transmitters will be replaced wi.th environmentally qualified transmitters.
Due to the long lead times necessary to engineer and procure components, this modification will be performed during the second refueling outage from now.
This outage is currently scheduled for late 1988.
Consumers Power Company is however, continuing to evaluate the necessity of providing environmentally qualified flow transmitters in this system.
This evaluation is based on the operator informa-tion needs identified in the upgraded EOPs and the results of the DCRDR.
If this evaluation shows that environmentally qualified equipment is not required, Consumers Power Company will notify the NRC and provide the appropriate justification for not qualifying this equipment.
MI0386-0897A-TC01-NL04 Palisades Plant Response to NRC Interim Report Conformance to Regulatory Guide 1.97 April 30, 1986 8
Other components of the HPSI flow indication instrument loop are located in mild environments and, thus, are not subject to the provisions of 10CFRS0.49.
M.
Flow in Low Pressure Safety Injection (LPSI) System The LPSI flow transmitters are located inside containment and have not been environmentally qualified.
Because these instruments provide the most direct method to monitor and control LPSI flow during postulated accident conditions, the flow transmitters will be replaced with environmentally qualified transmitters.
Due to the long lead times necessary to engineer and procure components, this modification will be performed during the second refueling outage from now.
This outage is currently scheduled for late 1988.
Consumers Power Company is however, continuing to evaluate the necessity of providing environmentally qualified flow transmitters in this system.
This evaluation is based on the operator informa-tion needs identified in the upgraded EOPs and the results of the DCRDR.
If this evaluation shows that environmentally qualified equipment is not required, Consumers Power Company will notify the NRC and provide the appropriate justification for not qualifying this equipment.
Other components of the LPSI flow indication instrument loop are located in mild environments and, thus, are not subject to the provisions of 10CFRS0.49.
N.
Refueling Water Storage Tank Level At Palisades, the function of the refueling water storage tank is performed by the Safety Injection and Refueling Water tank (SIRW).
The components which comprise the SIRW tank level instrumentation loop are all located in mild environments and, thus, are not I
subject to the provisions of 10CFRS0.49.
MI0386-0897A-TC01-NL04 Palisades Plant Response to NRC Interim Report Conformance to Regulatory Guide 1.97 April 30, 1986
- 0. Primary System Safety Relief Valve Positions 9
Acoustic monitors are located on the downstream piping of the three pressurizer safety valves and the two PORV's to detect flow indi-cating that the valves are open.
The portions of this valve position indication system located inside containment were upgraded during the 1985 refueling outage to meet environmental qualifica-tion requirements.
Other portions of the primary system safety relief valve position indicating system are located in mild envi-ronments and, thus, are not subject to the provisions of 10CFRS0.49.
P.
Pressurizer Heater Status Pressurizer heater status is monitored by anuneters measuring current flow to the heaters.
All components of the current measur-ing loop are located in mild environments and, thus, are not subject to the provisions of 10CFRS0.49.
Q.
Steam Generator Level Each of the two steam generators is provided with redundant wide range level indication which.measures from near the tube sheet to the steam separators.
Those portions of the steam generator level instrument loop located inside containment, including the level transmitters were upgraded to meet environmental qualification requirements during the 1983 refueling outage.
Other portions of the steam generator level instrument loop are located in mild environments and, thus, are not subject to the provisions of 10CFRS0.49.
MI0386-0897A-TC01-NL04
~
Palisades Plant Response to NRC Interim Report Conformance to Regulatory Guide 1.97 April 30, 1986 R.
Steam Generator Pressure 10 There are four pressure transmitters per steam generator having a range of 0-1,000 psig located inside containment.
These transmit-ters were replaced during the 1985 refueling outage with environmentally-qualified equipment.
Other portions of the steam generator pressure instrument loops are located in mild environ-ments and are not subject to the provisions of 10CFRS0.49.
S.
Safety/Relief Valve Position or Main Steam Flow The purpose of this indication is to monitor for potentially stuck open steam generator relief valves.
Palisades has main steam flow instrument loops with flow transmitters located inside containment which can be utilized to monitor for excessive steam flows which would result from stuck open steam generator relief valves.
The steam generator relief valves are located outside containment, and a Main Steam Line Break (MSLB) resulting from a stuck open relief valve would not result in a harsh environment inside of contain-ment.
Based on the above, it is concluded that the main steam flow instrument loops are located in a mild environment for events (MSLB outside containment) during which it would be required to function and, thus, are not subject to the provisions of 10CFRS0.49.
T.
Auxiliary or Emergency Feedwater Flow The control and indicating instrument loops for the auxiliary feedwater system were replaced with new components during the 1983 refueling outage.
The flow transmitters, located in a potentially harsh environment, were replaced with equipment meeting environmen-tal qualification requirements.
Other portions of the auxiliary feedwater flow indication instrument loops are located in mild environments and, thus, are not subject to the provisions of 10CFRS0.49.
MI0386-0897A-TC01-NL04 Palisades Plant Response to NRC Interim Report Conformance to Regulatory Guide 1.97 April 30, 1986 U.
Containment Spray Flow 11 All components of the containment spray flow instrument loop are located in mild environments and, thus, are not subject to the provisions of 10CFRS0.49.
V.
Heat Removal by the Containment Fan Heat Removal System The function of the containment air coolers, during post Loss of Coolant Accident (LOCA) or MSLB inside containment, is to condense steam to limit the peak pressure reached in containment.
The containment air coolers are normally operating and switch over to emergency operation automatically when the safety injection systems are initiated.
Switchover to emergency operation consists of opening the emergency cooler discharge valves and tripping the non-emergency fan.
Indications available in the control room to monitor system status include:
- 1.
Cooler inlet and outlet valve position
- 2.
Cooler fan status
- 3.
Service water pump status The containment cooler inlet and outlet valves are the only equip-ment whose status must be obtained from components located in a harsh environment.
The position switches for these valves are located inside containment.
These position switches were upgraded during the 1985 refueling outage with environmentally qualified equipment.
Cooler fan status and service water pump status is obtained from circuit breaker auxiliary contacts.
These circuit breakers are located in a mild environment.
The indicating lights for the valves, fan and pump status are indicated in the control room, which is a mild environment.
Equipment located in mild environ-ments is not subject to the provisions of 10CFRS0.49.
MI0386-0897A-TC01-NL04 Palisades Plant Response to NRC Interim Report Conformance to Regulatory Guide 1.97 April 30, 1986 W.
Containment Atmosphere Temperature 12 Containment atmosphere temperature indicating loops are provided for routine surveillance of containment temperature during normal operations.
The temperature elements associated with these loops are located in containment and have not been environmentally qualified.
Qualified containment pressure indicating loops are, however, provided which can be utilized to assess containment temperature.
During accident conditions, when energy is released to the containment, the saturation temperature corresponding to the containment pressure provides a close approximation of the actual containment atmosphere temperature.
As there are no post-accident operator actions required based, on knowledge of containment temperature, CPCo considers that containment pressure is an accept-able alternative for monitoring containment temperature.
X.
Containment Sump Water Temperature The Palisades design does not contain provisions for monitoring sump water temperature.
Monitoring containment pressure, however, allows an assessment of sump temperature as the sump temperature will be equal to or less (ie, slightly subcooled) than the satura-tion temperature corresponding to the containment pressure.
As there are no operator actions required, based on knowledge of containment sump water temperature, CPCo considers that containment pressure is an acceptable alternative for monitoring containment sump water temperature.
Y.
Makeup Flow-In All components of the charging (makeup) flow instrument loop are located in mild environments and, thus, are not subject to the provisions of 10CFRS0.49.
MI0386-0897A-TC01-NL04 Palisades Plant Response to NRC Interim Report Conformance to Regulatory Guide 1.97 April 30, 1986 Z.
Letdown Flow-Out 13 All components of the letdown flow instrument loop are located in mild environments and, thus, are not subject to the provisions of 10CFRS0.49.
AA.
Volume Control Tank Level All components of the volume control tank level instrument loop are located in mild environments and, thus, are not subject to the provisions of 10CFRS0.49.
BB.
Component Cooling Water Temperature to ESF System The CCW heat exchanger outlet temperature is measured by tempera-ture elements located in a room in the Auxiliary Building which is subject to a harsh environment.
However, temperature and radiation levels are only slightly elevated at this location during design basis events.
For this reason, it is expected that the existing temperature element would continue to perform its function in the postulated post-accident environment.
Nevertheless, this tempera-ture element will be evaluated to determine if it can survive the postulated post accident service conditions at its current loca-tion.
This evaluation will be complete by September 1986.
If the analysis shows that the existing temperature element cannot meet environmental qualification requirements, it will be replaced with an environmentally qualified component by the end of the next refueling outage currently scheduled for mid-1987.
Consumers Power Company is however, continuing to evaluate the necessity of providing environmentally qualified flow transmitters in this system.
This evaluation is based on the operator in-formation needs identified in the upgraded EOPs and the results of the DCRDR.
If this evaluation shows that environmentally qualified equipment is not required, Consumers Power Company will notify the NRC and provide the appropriate justification for not qualifying this equipment.
Palis-ades Plant Response to NRC Interim Report Conformance to Regulatory Guide April 30, 1986 14
- 1. 97 Components of the CCW heat exchanger outlet temperature inst;rument loop other than the temperature elements, are located in mild environments and, thus, are not subject t_o the provisions of 10CFRS0.49.
CC.
Emergency Ventilation Damper Position Emergency ventilation dampers controlling containment ventilation are considered containment isolation valves and are addressed in our response to Item F above.
Other ventilation dampers provide for emergency ventilation of the control room.
Position indication for these dampers is provided by equipment located in mild environments and, thus, is not subject to the provisions of 10CFRS0.49.
DD.
Status of Standby Power and Other Energy Sources Important to Safety Status of the standby electrical system is provided by indications of voltage, current and, in some cases, power of the start-up transformers, major lE electrical buses and the diesel generators.
Additionally, alarms are provided to indicate potential failures or problems associated with major components of the standby electrical system.
Components associated with providing this status informa-tion are located in mild environments and, thus., are not subject to the provisions of 10CFRS0.49.
Other standby energy sources include emergency high press~re air systems utilized to operate selected air operated valves in the event that the normal instrument air system is disabled.
Status of the various standby pressure sources is provided by local pressure indications and control room alarms actuated on low pressure.
The accumulator tanks in the standby high pressure air systems.are passive devices which function automatically to provide air to required valves through appropriate check valves in the event
- normal instrument air is lost.
The status indications provided are MI0386-0897A-TC01-NL04 i
Palisades Plant Response to NRC Interim Report Conformance to Regulatory Guide April 30, 1986 15 1.97 used for monitoring during normal operations to assure that suffi-cient air is available in the accumulators to perform their func-tion if required.
Some of the components of the status indication system are located in harsh environments, however, as these indica-tions are only required to determine system availability prior to use, CPCo considers that upgrading these components is not required.
NRC Position
- 2.
Seismic qualification requirement deviation - the licensee should show that these four variables conform to the original design basis seismic requirements or upgrade the instrumentation so that the seismic requirements are met (Section 3.3.2).
CPCo Response A.
Neutron Flux No seismic qualification requirements were imposed on the wide-range neutron flux monitoring instrumentation when Palisades was originally licensed.
As noted in the response to Item l.A above, neutron flux monitoring equipment will be upgraded during the second refueling outage from now.
This upgrade will include seismic qualification of the upgraded instrument loop.
Consumers Power Company is however, continuing to evaluate the necessity of providing qualified instrumentation for this system.
This evaluation is based on the operator information needs ident-ified in the upgraded EOPs and the results of the DCRDR.
If this evaluation shows that qualification is not required, Consumers Power Company will notify the NRC and provide the appropriate justification for not qualifying this equipment.
MI0386-0897A-TC01-NL04 Palisades Plant Response to NRC Interim Report Conformance to Regulatory Guide April 30, 1986
- 1. 97 B.
Reactor Coolant System (RCS) Cold Leg Water Temperature 16 Temperature elements (RTD's) measuring cold leg temperature were upgraded during the 1985 refueling outage with seismically and environmentally qualified components.
The temperature transmit-ters, indicators and recorder located in the control room were not required to be seismically qualified when the plant was originally licensed.
Two loops of wide range cold leg temperature indication with seismically qualified components will be installed during the next refueling outage currently scheduled for mid-1987.
C.
RCS Hot Leg Water Temperature Temperature elements (RTD's) measuring hot leg temperature were upgraded during the 1985 refueling outage with elements meeting current seismic and environmental qualification requirements.
The temperature transmitters, indicators and recorders located in the control room were not required to be seismically qualified when the plant was originally licensed.
Two loops of wide range hot leg temperature indication with seismically qualified components will be installed during the next refueling outage currently scheduled for mid-1987.
D.
RCS Pressure RCS pressure transmitters, loop power supplies and indicators were upgraded with seismically-qualified components during the 1985 refueling outage.
The recorders were not upgraded at this time, but will be replaced with seismically-qualified components during the next refueling outage currently scheduled for mid-1987.
The range of the installed RCS pressure instrument loops will be 0-3,000 psia following completion of instrument loop modifications planned for the next refueling outage.
This range deviates from the 0~4,000 psig range required by Regulatory Guide 1;97.
CPCo MI0386-0897A-TC01-NL04 Palisades Plant Response to NRC Interim Report Conformance to Regulatory Guide April 30, 1986 17 1.97 considers the 0-3,000 psia range to be adequate based on the improved readability of the smaller range and proposed Anticipated Transient Without Scram (ATWS) modifications required by 10CFR50.62, which greatly reduce the probability of an ATWS.
NRC Position
- 3.
RCS cold leg temperature - the licensee should change the existing power supply for the recorder to a Class lE power source (Section 3.3.4).
CPCo Response The power supply to the cold leg temperature recorder will be changed to provide power from a Class lE power source during the next refueling outage.
(See also_response to Item 2.B above.)
NRC Position
- 4.
RCS pressure - the licensee should provide redundant channels and Class lE power for the instrumentation for this variable (Section 3.3.5).
CPCo Response Redundant seismically and environmentally-qualified pressure tra~smitters powered from separate Class lE power sources were installed during the 1985 refueling outage.
Each transmitter provides indication in the control room on separate indicators.
Seismically-qualified and Class lE powered recorders, monitoring at least one channel of RCS pressure, will be provided during the next refueling outage as discussed in Item 2.D above.
An exception to the range requirement for C-E plants is also discussed in Item 2.D.
MI0386-0897A-TC01-NL04
Attachment I Palisades Plant Response to NRC Interim Report Conformance to Regulatory Guide April 30, I986 NRC Position 18
- 1. 97
- 5.
Containment isolation valve position - the licensee should provide redundant Class IE power sources (Section 3.3.8).
CPCo Response Each containment penetration requiring isolation has two valves in series with control power provided from different trains of Class IE power.
Either of these valves is capable of performing the isolation function.
Position indication for each valve is powered from the same Class IE division of power as the valve control circuitry. Failure of a single-power source results in the loss of position indication of one of the valves, but the position indica-tion of the redundant valve performing the isolation function remains powered.
Table I, Item 2 of Re~ulatory Guide I.97 Revision 3 states that "Within each redundant division of a safety system, redundant monitoring channels are not needed II CPCo considers that this applies to the power supply for redundant monitoring channels and that redundant power to each channel of the containment isolation valve position indicators is not required.
NRC Position
- 6.
Pressurizer level - the licensee should upgrade this instrumenta-tion to Category I (Section 3.3.II),
CPCo Response One pressurizer level instrument loop was upgraded during the I985 refueling outage.
This upgrade replaced the level transmitter with an environmentally and seismically-qualified instrument.
Level indication also was upgraded with a seismically-qualified indicator MI0386-0897A-TCOI-NL04 Palisades Plant Response to NRC Interim Report Conformance to Regulatory Guide April 30, 1986 19 1.97 (indication provided in the control room is located in a mild environment and not subject to 10CFRS0.49).
An additional pressur-izer level instrument loop will be upgraded to bring the pressur-izer level variable into compliance with Regulatory Guide 1.97, Category 1 requirements. Due to the long lead times necessary to engineer and procure components, this modification will be per-formed during the second refueling outage from now, currently scheduled for late 1988.
NRC Position
- 7.
Quench tank temperature - the licensee should provide instrumenta-tion that covers the tank saturation temperature (Section 3.3.13).
CPCo Response The quench tank is a passive device designed to receive and con-dense discharges from the pressurizer safety and/or power operated relief valves (PORV) and prevent these discharges from reaching the containment environment.
The quench tank is provided with a rupture disk to relieve a quench tank overpressure condition equal to the design pressure of the tank (100 psig).
The only event which could result in excessive temperatures in the quench tank would be a stuck open primary coolant system safety and/or power operated relief valve (PORV).
Indication of these valves being stuck open is provided by qualified position indication.
Quench tank temperature indication would only provide confirmatory indica-tion that the safety and/or PORV valves were stuck open.
This confirmatory indication would be provided even if the temperature indicated off scale high.
As quench tank temperature indication only provides confirmatory information, and as there are no opera-tor actions required based solely on quench tank temperature, CPCo considers that the existing range of 0-300°F is adequate.
MI0386-0897A-TC01-NL04
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Palisades Plant Response to NRC Interim Report Conformance to Regulatory Guide 1.97 April 30, 1986 NRC Position
- 8.
Quench tank pressure - the licensee should provide the 0 to 100 psig recommended range (Section 3.3.14).
CPCo Response 20 The quench tank is a passive device designed to receive and con-dense discharges from the pressurizer safety and/or power-operated relief valves (PORV) and prevent these discharges from reaching the containment environment.
The quench tank is provided with a rupture disk to relieve a quench tank overpressure condition equal to the design pressure of the tank (100 psig).
The only event which could result in excessive pressures in the quench tank would be a stuck open primary coolant system safety and/or power-operated relief valve (PORV).
Indication of these valves being stuck open is provided by qualified position indication.
Quench tank pressure would only provide confirmatory indication that the safety and/or PORV valve were stuck open.
This confirmatory indication would be provided even if the pressure indication were off scale high.
Further, increasing the range of the quench tank pressure indica-tion loop would decrease the sensitivity of the reading required during normal operation of the system.
As quench tank pressure indication only provides confirmatory information, and as there are no operator actions based on solely quench tank pressure, and as a decrease in sensitivity*would result if the range were increased, CPCo considers that the existing range of 0-25 psig is adequate for the intended function.
NRC Position
- 9.
Steam generator level - the licensee should upgrade this instru-mentation to include seismic qualification (Section 3.3.15).
MI0386-0897A-TC01-NL04 Palisades Plant Response to NRC Interim Report Conformance to Regulatory Guide 1.97 April 30, 1986 CPCo Response 21 Wide-range steam generator level instrumentation monitoring an effective range from the tube sheets to the steam separators was incorporated into the plant design during the 1983 refueling outage.
The instrumentation provided meets the environmental and seismic qualification requirements of Regulatory Guide 1.97 (see also response to Item l.Q above).
Narrow-range steam generator level instrumentation, monitoring the normal steam generator operating band, was upgraded to meet envi-ronmental and seismic qualification requirements during the 1985 refueling outage.
This instrumentation loop would be utilized by the operator to determine the affected steam generator following a Steam Generator Tube Rupture (SGTR).
The upgraded narrow-range instrument loop presently meets the Category 1 requirements of Regulatory Guide 1.97 for Type A variables.
NRC Position
- 10.
Steam generator pressure - the licensee should upgrade this instru-mentation to Category 1 (Section 3.3.16).
CPCo Response Steam generator pressure instrumentation loops were upgraded during the 1985 refueling outage to meet redundancy, seismic and environ-mental qualification recommendations of Regulatory Guide 1.97 (see also response to Item 1.R above).
The upgraded instrument loops do not meet the recommended range of Regulatory Guide 1.97 (ie, from atmospheric pressure to 20% above the lowest safety valve setting).
The installed pressure instrumentation monitors from 0-1,000 psig which is 1.5% above the lowest safety valve setting of 985 psig.
MI0386-0897A-TC01-NL04
Palisades Plant Response to NRC Interim Report Conformance to Regulatory Guide April 30, 1986 22
- 1. 97 Each steam generator has a total of 12 safety relief valves with lift set points ranging from 985 psig to 1,025 psig.
The number of relief valves and relieving capacity available act to limit the steam generator pressures to values only slightly greater than the indicating range of the pressure instrumentation.
During design basis events (ie, MSLB or LOCA), steam generator pressure falls to values lower than normal operating pressures due to the inherent overcooling of these type events.
Increasing the range of the steam generator pressure indication loop would reduce the sensitiv-ity and accuracy of the instrumentation loop for normal operation and for conditions which result in a reduction of steam generator pressure.
CPCo concludes that the existing range of the steam generator pressure instrument loop is acceptable for monitoring steam generator pressure during normal and accident conditions.
This is based on the relieving capacity and set point of the steam genera-tor safety valves which limit pressures to small, short duration excursions above the existing range.
It also is based on maintain-ing the existing sensitivity and accuracy of the instrument loop for monitoring pressures during normal op*erations and during upsets which result in pressure reductions.
NRC Position
- 11.
Main feedwater flow - the licensee ~hould state the design flow and justify the deviation (Section 3.3.17).
CPCo Response Our original submittal inadvertently stated that main feedwater flow indication covered a range from 0-12,000 gpm.
The correct range is 0 - 12 x 106 lbs/hr (ie, one instrument per feedwater train measuring 0 - 6 x 106 lb.s/hr).
Based on heat balances,. the maximum design feedwater flow is 11.25 x 10 6 lbs/hr.
This results MI0386-0897A-TC01-NL04 Palisades Plant Response to NRC Interim Report Conformance to Regulatory Guide April 30, 1986 23 1.97 in a 6.7% margin between design feedwater flow and the upper limit of the existing indication.
Although not meeting the 10% margin recommended by Regulatory Guide 1.97, the provided margin only deviates slightly and is sufficient for monitoring potential overfeed occurrences.
NRC Position
- 12.
Condensate storage tank water level - environmental qualification for the power source for this variable should be addressed in accordance with 10CFRS0.49; data should be provided that shows that the seismic qualification for the power source conforms to that required at the time of plant licensing (Section 3.3.18).
CPCo Response The power supply for the condensate storage tank level indication is located in a mild environment and is, thus, not subject to the provisions of 10CFRS0.49.
The instrument loop power supply will be upgraded by the end of the next refueling outage with seismically-qualified components.
NRC Position
- 13.
Component cooling water flow to ESF system - the licensee should provide this instrumentation for monitoring the operation of the cooling water system (Section 3.3.22).
CPCo Response During post DBA conditions, the component cooling water (CCW) system functions to supply cooling water to the engineered safe-guard pump seal glands and to the shutdown cooling (SDC) heat exchangers.
Proper operation of these functions can be determined by monitoring CCW pump status and the status of valves required to MI0386-0897A-TC01-NL04
Palisades Plant Response to NRC Interim Report Conformance to Regulatory Guide April 30, 1986 24
- 1. 97 be open..
CCW pump status is provided by auxiliary contacts located at the pump switchgear and indicating lights located in the control room.
These components are located in a mild environment.
Valve status indication is provided by position switches located on the valves and indicating lights located in the control room.
Valve position switches required to be monitored to determine CCW system status, which are located in a harsh environment, were replaced with environmentally-qualified components during the 1985 refueling outage.
Other components of the valve position indication instru-mentation are located in mild environments and, thus, are not subject to the provisions of 10CFRS0.49.
The Palisades CCW system is designed to provide for full pump flow through the SDC heat exchangers and ESF pump seals during post-DBA conditions.
CCW flow control is not required*and no capability to control CCW to these components other than on/off is provided.
As the only flow control available is on/off, the status information provided to determine pump and valve status is an acceptable alternative to monitoring CCW flow in the Palisades design.
NRC Position
- 14.
Radioactive gas holdup tank pressure - the licensee should provide the recommended range or show that the existing range cannot be exceeded (Section 3.3.23).
CPCo Response The radioactive waste gas system consists of a waste gas surge tank, three air compressors and six waste gas decay tanks.
The design pressure of the waste gas decay tanks is 120 psig and pressure-monitoring instrumentation is provided to indicate from O psig to design pressure (120 psig).
This range of the pressure instrumentation is considered acceptable based on the following MI0386-0897A-TC01-NL04 Palisades Plant Response to NRC Interim Report Conformance to Regulatory Guide 1.97 April 30, 1986 25 operating and design features which prevent the design pressure of the tank from being exceeded:
- a.
During normal operation the tanks are isolated when reaching 95 psig (80% of design pressure).
- b.
An alarm is provided to indicate when tank pressure exceeds 100 psig (83% design pressure}.
- c.
Two relief valves set at tank design pressure are available to relieve pre~sure when the tank is being filled.
One relief is located on the discharge of the air compressors and the other on the tank.
The total relief valve capacity exceeds the design capacity of the pumping system.
The relief valves relieve back to the waste gas surge tank.
- d.
The tanks are located in an area of the plant where the envi-ronment would be unaffected during any design basis event.
Thus, isolated tanks could not be overpressured by extreme temperature changes.
NRC Position
- 15.
Particulates and halogens - the licensee should provide sampling points and analysis equipment that meets the range and Category 3 requirements of Regulatory Guide 1.97 (Section 3.3.24).
CPCo Response All aspects of this recommendation are met.
The radioactive gaseous effluent monitoring system (RGEMS) monitors the gaseous effluent from the plant stack.
RGEMS provides sampling and analy-sis during normal operation of the plant as well as during emergen-cy conditions.
It is designed to assist in plant recovery operations in accordance with the requirements of NUREG 0737, MI0386-0897A-TC01-NL04
J Palisades Plant Response to NRC Interim Report Conformance to Regulatory Guide 1.97 April 30, 1986 26 Section II.F.1. (Note:
The requirements of Reg. Guide 1.97 reflect those presented in NUREG 0737.)
The major equipment of RGEMS is a normal range noble gas monitor (RIA-2326, range 10 101 Ci/sec), high range noble gas monitor RIA-2327, range 10 106 Ci/s), normal range iodine/particulate detection loop (RIA-2325, range 10 1 -
106 CPM), high range iodine/
particulate filter and automatic grab sample capabilities.
Isokinetic sampling of the stack flow ensures a representative sample is obtained.
Noble gas monitoring is performed using off-line detectors with remote readout in the control room.
Iodine and particulates are collected continuously using silver zeolite and filter media.
Silver zeolite cartridges and particulate filters are subsequently removed for onsite analysis.
Onsite analysis consists of gross ~' y analysis of the particulate filter and gamma ray spectroscopy of the particulate filter and silver zeolite cartridge using the equipment described in response to Item 18.
The output of the gaseous effluent monitoring system is displayed in units of Ci/sec rather than in units of µCi/cc as recommended by Regulatory Guide 1.97.
Use of Ci/sec display units reduces the time necessary to convert the reading to an offsite dose and was approved by the NRC by letter dated April 20, 1984 (Reference 6).
NRC Position
- 16.
Airborne radiohalogens and particulates - the licensee should provide portable sampling equipment and onsite analysis instrumen-tation that will read 10- 9 to 10- 3 µCi/cc (Section 3.3.25).
MI0386-0897A-TC01-NL04
Palisades Plant Response to NRC Interim Report Conformance to Regulatory Guide 1.97 April 30, 1986 CPCo Response 27 All aspects of this recommendation are met.
Emergency Implementing Procedure EI-16.1 provides a detailed list of the equipment that is available for emergency use.
A minimum of six portable air sam-plers (RADECO 809V) are dedicated solely for emergency response.
An additional 40 samplers are available from the Radiation Safety instrument inventory.
EI-16.1 also specifies a large number of silver zeolite cartridges and particulate filters for use in portable air samplers.
EI-16.1 specifies a minimum of eight portable count rate instruments (Eberline PRM-6 w/ HP 210 probe) that are to be used for gross analysis of iodine and particulate radioactivity.
EI-8 provides the methodology for performing the analysis.
This instrumentation is capable of determining approxi-mate airborne concentrations in the range of 10 10-3 µCi/cc.
In addition to the portable counting equipment described above, all samples may be counted using the equipment described in response t6 Item 18.
NRC Position
- 17.
Plant and environs radiation - the licensee should provide Category 3 portable instrumentation with a range of 10-3 to 104 R/hr, photons and 10-3 to 104 rads/hr, beta radiation and low-energy photons (Section 3.3.25).
CPCo Response The aspects of this recommendation are met.
The Plant has. three Eberline R0-7 portable survey instruments which have the capability to measure both beta and gamma radiation in the range of 1 x 10 (
2 x 104 R/hr.
MI0386-0897A-TC01-NL04
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Palisades Plant Response to NRC Interim Report Conformance to Regulatory Guide 1.97 April 30, 1986 NRC Position 28
- 18.
Plant and environs radioactivity - the licensee should provide portable instrumentation, such as a portable multichannel gamma ray spectrometer, to monitor areas throughout the facility and site environs (Section 3.3.25).
CPCo Response The Palisades Plant does not have a portable multichannel gamma ray spectrometer, however, the Plant does have the capability to collect samples from any area within the Plant or from the site environs.
The samples would be transported to the high level counting room in Access Control which contains two detectors (GeLi and Intrinsic) powered by a Nuclear Data 6620 multichannel analyz-er.
The analyzer is located in the low level counting room.
These detectors are used during normal plant operations and background permitting, would also be use during accident conditions.
Should these detectors be unavailable due to high background, a third detector (Intrinsic) located in the low level counting room and powered by a ND 6685 would be used.
MI0386-0897A-TC01-NL04 Palisades Plant Response to NRC Interim Report Conformance to Regulatory Guide 1.97 April 30, 1986 III.
References 29
- 1.
NRC letter, D G Eisenhut to all licensees of operating reactors, applicants for operating licensees and holders of construction permits, "Supplement 1 to NUREG-0737-Requirements for Emergency Response Capability, (Generic Letter 82-33)," December 17, 1982.
- 2.
Instrumentation for Light-Water-Cooled Nuclear Power Plants to Access Plant and Environs Conditions During and Following an Accident, Regulatory Guide 1.97, Revision 2, US Nuclear Regulatory Commiss.ion (NRC), Office of Standards Development, December 1980.
- 3.
Consumers Power Company letter, K A Toner to Dennis M Crutchfield, Chief Operating Reactor Branch No. 5, "Regulatory Guide 1.97, Interim Report of Deviations," December 13, 1983.
- 4.
Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident, Regulatory Guide 1.97, Revision 3, US Nuclear Regulatory Commission (NRC), Office of Standards Development, May 1983.
- 5.
NRC letter, John A Zwolinski (NRC) to David J VandeWalle (CPCo),
"Conformance to Regulatory Guide 1. 97," dated June 24, 1985.
- 6.
NRC letter, Dennis M Crutchfield (NRC) to David J VandeWalle (CPCo), "NUREG 0737 Item II.F.1.1," dated April 20, 1984.
MI0386-0897A-TC01-NL04