ML18052A462
| ML18052A462 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/09/1986 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8606120314 | |
| Download: ML18052A462 (4) | |
Text
r consumers Power JIOWElllN&
MICHlliA#'S flROliRESS General Offices:
1945 West Parnell Road, Jackson, Ml 49201 * (517) 788-1636 June 9, 186
- Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
Kenneth W Berry Director Nuclear Licensing SUPPLEMENT 1 TO NUREG-0737 - REVISION TO PROCEDURES GENERATION PACKAGE By letter dated May 23, 1986, Consumers Power Company submitted to the NRC the Procedures Generation Package (PGP) that would be used to develop the upgraded Emergency Operating Procedures (EOP) for the Palisades Plant. to that letter provided a description of the deviations from and additions to the Generic Technical Guidelines (ie, Combustion Engineering CEN-152, Rev 2) that were of safety significance and that would be incorporated into the Palis~des Plant upgraded EOPs.
In addition to describing the deviations and/or additions to the Generic Technical Guidelines incorporated into the upgraded EOPs, provided the technical justification for each deviation/addition.
During subsequent review of Attachment 1, a concern was raised that the technical justification for not providing specific, post accident, containment hydrogen concentration limits might mislead a reviewer with regard to the operability of the containment hydrogen monitor system.
The current statement, item 15.b of Attachment 1, could be interpreted to mean that the hydrogen monitor is in operation during normal Plant operation.
This is not the case.
As noted in the Palisades FSAR UPDATE, Section 9.9, during normal Plant operation, the hydrogen monitoring system is maintained in a standby condition.
This mode of operation prevents condensation of water in the sample lines and allows rapid startup from either the control room or the local control panel in the event that conditions are such that hydrogen generation is possible.
Once started, operation of the hydrogen monitoring system is automatic.
OC0686-0021S-NL01
Director, Nuclear Reactor Regulation Palisades Plant Revision to PGP June 9, 1986 2
To ensure that the technical justification for deviating from the Generic Technical Guideline for specific hydrogen concentration monitoring is unambiguous, item 15. b of Attachment 1 has been revised td more clearly describe the status of the hydrogen monitoring equipment.
Therefore, pleaie replace pages 7 and 8 of Attachment 1 to Consumers Power Company letter dated May 23, 1986 with the attached pages.
The revision is indicated by a vertical line in the right hand margin.
Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment OC0686-0021S-NL01
.ADDITION/DEVIATION FROM CEN-152, REV 02 when containment temperature exceeds 175°F or when!
containment pressure exceeds 3 psig.
- 15) Containment Atmosphere Criteria in Reactor Trip Recovery, Loss of Forced Circulation, and Standard Post Trip Actions will only include containment temperature and containment pressure.
(No specific
.hydrogen concentration limit.)
OC0586-0020A-NL01-Al AFFECTED UPGRADED.EOPs Standard Post Trip Actions, EOP 1.0 Reactor Trip Recovery, EOP 2.0 Loss Of Forced Circulation, EOP 3.0 a) b)
c) 1*
7 TECHNICAL JUSTIFICATION Minimum EEQ Qualification Test Parameters (175 °F /3 psig) *. Increased instrument error factors have been added to the curves for mini~um subcooling, pressurized thermal shock prevention, and steam generator primary to secondary differential pressure limitations. *
(Reference Engineering Analysis EA-FC567-03).
All CEN-152, Rev02~* EOPs have *~pecified a measurement of ~ontainment hydrogen by hydrogen monitors.
During normal Plant operation, the hydrogen monitor system is maintained in standby conditions permitting rapid startup from the control room or local control panel per FSAR UPDATE Section 9.9.
The use of Optimal. Recovery Procedures where the mechanisms for containment hydrogen operation do riot exist Js.*
confirmed by normal containment temperature and pressure.
A high containment temperature would indicate a possible LOCA with possible zirconium hydriding, or the possible generation of hydrogen from containment spray flow corroding in-containment metal surfaces.
A high containment pressQre could indi~ate a LOCA or the conditions resulting in the containment spray corrosion effect.
d)
The absence of high containment temperature or pressure when these
- 17) Palisades analysis results in Simultaneous Hot/Cold leg
- Safety Injection Criterion of 5.5 to 6.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> following LOCA initiatt9n.
OC0586-002QA-NL01-Al LOCA, EOP 4.0 Functional Recovery Procedure, EOP 9.0 Power) to NRR dated October ':J, L':JtH.
a)
CEN-152, Rev 02, requires plant specific technically developed values for this time band.
- b)
"5.5 to 6~5 hours" is based on conservatively calculating the depletion of the Condensate Storage Tank (not replenished) due to S/G steaming during the accident.
This leads to the follow-on assumption of a loss of feedwater with consequential init.iation of once through cooling through the PORVs.
~..,
c)
Therefore it is conservatively assumed that forced or natural circulation will not be available for boric acid dispersion regardless of primary break size after 5.5*
to 6.5 ~ours.
d)
This leaves simultaneous hot/cold leg in-jection as the only mechanism for prevent-
~
ing boric acid precipitation, if shutdown cooling system flow can not be initiated.
.**,.*