ML18052B400
| ML18052B400 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/01/1987 |
| From: | Kuemin J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML18052B401 | List: |
| References | |
| NUDOCS 8712080077 | |
| Download: ML18052B400 (4) | |
Text
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consumers Power POW ERi Nii 11/llCHlliAN'S PROliRESS General Offices: 1945 West Pernell Road, Jackson, Ml 49201 * (517) 788-0550 December 1, 1987 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
UPDATE INSERVICE PUMP AND VALVE PROGRAM Enclosed are copies of Palisades Engineering Manual Procedures EM-09-02, entitled "Inservice Testing of Plant Valves" and EM-09-04, entitled "Inservfce Testing of Selected Safety Related Pumps."
These procedures have been revised from previous submittals, and incorporate an ASME Boiler and Pressure Vessel (B&PV) Code,Section XI, edition update to the 1983 'edition summer 1983 addenda, as allowed by 10CFR50.55a.
The Code update provides consistency to the Code edition for the ten-year inservice inspection interval for class 1, 2, and 3 systems and components which ends in January 1994.
The enclosed procedures represent the basis for the Palisades pump and valve inservice inspection program.
Revision to EM-09-02 includes addition of the containment hydrogen monitoring isolation valves within its scope (refer to Violation in NRC letter June 11, 1987 and CPC response July 13, 1987).
EM-09-04 reflects a change in the pump test interval from monthly to quarterly.
Additionally, both procedures contain relief requests from certain code requirements which have been determined to be impractical.
The relief requests require NRC approval per 10CFR50.55a(g)(b)(i). It is our intent to initiate the program update in January 1988.
The enclosed relief requests and program updates supersede all previous submittals that are discussed below.
By letters dated March 1, 1977, and May 3, 1977 Consumers Power Company submitted letters describing the Palisades Inservice Pump and Valve Testing Programs.
The March 1, 1977 letter requested relief from certain testing requirements.
Via letter dated December 7, 1977, the NRC granted interim relief, pending completion of a detailed review of the relief requests which are summarized as follows:
Pumps:
- 1.
System designs preclude measur-ing of pump suction pressures.
- 2.
Service water pumps do not permit measurement of bearing temperatures.
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Nuclear Regulatory Commission Palisades Plant Update Inservice Pump and Valve Progrcam December 1, 1987
- 3.
Charging pumps do not permit measurement of bearing temperatures.
- 4.
The concentrated boric acid pumps do not permit measurement of bearing temperatures but bearing housing temperature will be measured.
Valves:
- 1.
Seat leakage of category A containment isolat.ion valves need not be determined at full system functional differential pressure.
- 2.
Category C relief valve tests may be distributed over each refueling cycle.
An October 7, 1977, Consumers Power letter stated the relief request for valves, item 1 above, was unnecessary and also added two additional relief request items 3 and 4 as follows:
Valves:
- 3.
Normally open valves which are impractical to partial stroke during operations will be full stroke tested during each required cold shutdown.
- 4.
An alternate stroke time acceptance criteria for valves with stroke times less than 10 seconds was proposed.
2 Consumers Power consolidated the relief requests in a letter of June 13, 1978 which also proposed Technical Specifications changes along with an ISI program update.
The NRC issued Amendment No. 53 on October 15, 1979 which revised the Technical Specifications for inservice pump testing and granted relief from pump testing requirements for:
A.
Measurement of bearing temperatures for the service water, charging and concentrated boric acid pumps (items 2, 3, & 4 for Pumps above).
B.
Measurement of pump suction pressure (item 1 for Pumps above).
The relief requests for valves were not discussed in the NRC letter.
Subsequent update of the Palisades valve testing program on October 28, 1981, and August 6, 1982, which updated the program to the 1977 Code edition through the 1979 summer addenda and included relief requests also have not been responded to by the NRC.
On April 25, 1980, Consumers Power updated the inservice pump testing program to the 1977 edition of the ASME B&PV Code,Section XI, through the summer 1978 addenda.
This letter also contained additional relief requests summarized as follows:
- 1) flow and discharge pressure are not typically available, one or the other will be monitored, and 2) an alternate method of service water flow adequacy was proposed.
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e Nuclear Regulatory Commission Palisades Plant Update Inservice Pump and Valve Program December 1, 1987 3
An October 27, 1981 letter again updated the inservice pump testing program to 1977 edition through the summer 1979 addenda.
A copy of procedure EM-09-04 describing the inservice testing for pumps was provided on May 20, 1982.
On February 15, 1984, Consumers Power requested relief from monthly pump testing requirements to quarterly testing.
The last previous submittal concerning pump testing.was a letter of April 17, 1985 which provided an updated plot of service water differential pressure vs inlet temperature with two pumps operating.
The relief requests contained within the enclosed procedures EM-09-02 and EM-09-04 supersede all previously submitted requests.
It is our understanding of 10CFR50.55a(g)(5)(iv) that even though previous relief has been granted from certain pump testing requirements (i.e., bearing temperatures for service water, charging and concentrated boric acid pumps, and pump suction pressures), reapplication for relief is necessary when
- revising the inservice inspection program to an updated code edition and addenda.
Therefore, included within the attached relief requests are requests for relief from those requirements which have been previously approved by the NRC.
Copies of the Piping and Instrument Diagrams (P&IDs) referenced within the procedures are being provided with a copy of this letter to the NRC Palisades Project Manager.
These P&IDs are referenced in the relief requests and indicate relative valve, pump and instrument locations.
As committed to in our [[letter::PNO-III-87-053, on 870412,reactor Manually Tripped as Result of Leak in Electrohydraulic Control (EHC) Sys for Main Turbine.Caused by Fatigue Failure of Impeller of Pump in EHC Sys.Pump Repaired|April 13, 1987 letter]], Consumers Power Company has reviewed the relief requests in our pump and valve testing program to determine their appropriateness, in light of the experience gained from the augmented testing done during the 1986-1987 maintenance outage.
Our review did not indicate any of the relief requests to be inappropriate for the present plant configuration.
However, we have also initiated review of the pump inservice testing program to identify and propose improvements in test methods and test equipment.
The review is presently in progress with a goal to reduce the pump inservice testing relief requests.
We have incorporated the review and the subsequent plant modifications into the Palisades Five Year Plan.
These modifications are to resolve our commitment to upgrade the ISI pump testing program as described in our January 28, 1987 letter (Attachment IA item SC).
One of the proposed modifications, which is also an item Consumers Power Company has separately committed to resolve, is the upgrade of the service water pump flow instrumentation (CPC letter January 28, 1987 Attachment 5, item 5).
The scheduled completion of this particular modification is during the 1988 refueling outa~e.
The completion of the modifications will, as noted above, reduce the number of relief requests necessary.
Until those modifications are completed the relief requests will be required.
Accordingly, Consumers Power Company requests NRC review of the enclosed relief requests pursuant to 10CFR50.55a(g)(6)(i).
A previous fee payment of $4000.00 was made on September 23, 1980 for the pump inservice testing relief requests submitted on April 25, 1980.
Since no OC1187-0216-NL02
Nuclear Regulatory Commission Palisades Plant Update Inservice Pump and Valve Program December 1, 1987 response has been received concerning this earlier submittal, and those subsequent to it, we request the fee be applied to this request, in part, in lieu of the application fee pursuant to 10CFR170~12, with the remaining
$3850.00 to pe applied to the balance of the approval fee.
An inadvertent ommission in the procedures was made, which failed to identify the Code addenda as summer 1983.
A change to the procedure will be made.
Licensing Engineer CC Administrator, Region III, NRC NRC Resident Inspector - Palisades Attachments OC1187-0216-NL02 4