ML18058B302
| ML18058B302 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/29/1992 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-89-04, GL-89-4, TAC-M81064, NUDOCS 9301040146 | |
| Download: ML18058B302 (26) | |
Text
consumers Power
~-,, l'OWERIN&
MICHl&AN"S l'RO&RESS Palisades Nuclear Plant:
27780 Blue Star Memorial Highway, Covert, Ml 49043 December 29, 1992 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 GB Slade General Manager DOCKET 50-255 - LICENSE DPR PALISADES PLANT - INSERVICE TESTING (IST)
PROGRAM RELIEF REQUESTS, GENERIC LETTER 89-04 (TAC NO. M81064) - ADDITIONAL INFORMATION By letter dated June 28, 1991, Consumers Power Company submitted a revised Palisades. IST program.
The submittal superseded previous program revisions, reflected modification made during the 1990 refueling outage and indicated that compliance with Generic Letter (GL) 89~04 guidance had been achieved.
The NRC staff, with assistance from Brookhaven National Laboratory, reviewed and evaluated our response to GL 89-04 and the IST program relief requests that are part of our IST program.
The results of that review were provided in a Safety Evaluation Report (SER) and supplemented by the Brookhaven National Laboratory Technical Evaluation Report (TER) in the NRC's July 15, 1992 letter.
As stated in the SER, some of the requested reliefs were granted, some were granted based upon the NRC's stated interpretation of our request, and some relief requests were denied.
For those relief requests that were denied, the safety evaluation directed us to comply with the code requirements or submit a revised relief request within the 1irst.quarter after receiving the safety evaluation, except where interim relief had been granted.
Specific interim relief, for a period of one*year or until the end of the next refueling outage whichever is later, was granted for specific cases where the NRC determined that immediate imposition of the Code requirements would be an undue burden without a compensating increase in the level of safety. Attached is additional information concerning those items for which relief was denied in the NRC's July 15, 1992 Safety Evaluation Report and interim relief was not granted.
9301040146 921229 PDR ADOCK 05000255 p
PDR A CMS' ENERGY COMPANY contains individual responses to those TER items associated with the relief requests that have been denied and interim relief was not granted. contains our resubmitted relief requests that have been revised in response to NRC comments. contains the velocity range history for the containment spray and low pressure safety injection pumps.
?.:?/:?~~,4, Gerald B Slade 0
General Manager CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachments
ATTACHMENT 1 Consumers Power Company Palisades Plant Docket 50-255 INSERVICE TESTING (IST) PROGRAM RELIEF REQUESTS, GENERIC LETTER 89-04 (TAC NO. M81064)
ADDITIONAL INFORMATION RESPONSE TO TER ITEMS 5.6, 5.18, 5.19, 5.20, 5.22, 5.28, and 5.31 December 29, 1992 5 Pages
1 TECHNICAL EVALUATION REPORT - IST PROGRAM ACTION ITEMS TER ITEM 5.6 The NRG staff encourages the use of pump vibration velocity measurements, such as the program contained in ASME Operation and Maintenance Standard {O&M}
Part 6.
However, in Pump Relief Request 4, the licensee has provided insufficient information to evaluate the request.
The licensee is encouraged to revise and resubmit the request or adopt Code Case N-465 (TER Section 2.2).
In TER Section 2.2, the NRG staff asked the licensee to submit the following information:
Comment 1 The licensee should provide specific velocity ranges for the acceptable, alert and required action ranges.
Comment 2 The licensee should provide information on the vibration measurement requirements.
Comment 3 The licensee should clarify the pumps for which this relief applies.
CPCo Response Palisades does not desire to adopt Code Case N-465 at this time.
The following provides additional information to evaluate the relief request and also addresses the NRC staff questions.
Comment 1 Palisades will use those velocity range values listed in O&M Part 6 for the following pumps:
Service Water Pumps A, B and C (P-7A, B & C); Component Cooling Water Pumps A, Band C (P-52A, B
& C); Boric Acid Pumps A and B (P-56A and B), High Pressure Safety' Injection Pumps A and B (P-66A & B); Auxiliary Feedwater Pumps A, Band C (P-8A, B & C); and Charging Pumps A, Band C (P-55A, B &
C)~
The following pumps cannot repeatedly meet the velocity range requirements of O&M Part 6:
Containment Spray Pumps A, B and C (P-54A, B & C) and Low Pressure Safety Injection Pumps A and B (P-67A & B).
These pumps cannot meet these requirements because they are tested at low flow rates through a minimum recirculation line. Attachment 3 provides a brief velocity range history for these pumps.
Pump Relief Request 4 (in Attachment 2) contains the velocity range limits for those units that cannot meet the limits of the O&M standard. These limits were developed based upon past operating experiences.
2 Comment 2 Vibration measurements are taken in the vertical, axial and horizontal directions on each bearing measured.
The code requires that at least one bearing location is measured on each pump.
On the Component Cooling Water Pumps and the High Pressure Safety Injection Pumps, since both the inboard and outboard bearings are accessible, vibration measurements are taken on both bearings.
Once the Auxiliary Feedwater Pumps are switched to velocity measurements, both their inboard and outboard bearings will be measured as part of the program.
Comment 3 Relief request number 4 applies to the pumps listed in Attachment
- 2.
At the current time, the vibration velocity measurements are taken for the following pumps:
Service Water Pumps A, B and C; Containment Spray Pumps A, Band C; Component Cooling Water Pumps A, B and C; Charging Pumps A, B and C; High Pressure Safety Injection Pumps A and B; and Low Pressure Safety Injection Pumps A and B.
Also at the current time the vibration measurements for the Auxiliary Feedwater Pumps A, B and C, and Boric Acid Pumps A and B are using the vibration displacement method of evaluation.
The vibration displacement method for the Auxiliary Feedwater Pumps and the Boric Acid Pumps is in the process of being converted to vibration velocity. Once these pumps are converted to vibration velocity then all vibration measurements for the IST program will use this method.
TER ITEM 5.18 Based on the Jack of sufficient justification, it is recommended that relief be denied for the component cooling isolation valves stroke time requirements.
The licensee should test these valves in accordance with the code or revise and resubmit the relief request. Additionally, the Basis For Relief section of Valve Relief Request 12 requests relief from the stroke timing requirements specified by ASME Section XI, paragraph IWV-3414.
This is an incorrect reference.
Paragraph IWV-3413 defines the stroke time testing requirements for power operated valves (TER Section 3.3.1).
CPCo Response Valve Relief Request 12 has been revised to provide additional justification for not performing stroke time testing of the component cooling isolation valves (CV-0944 and CV-0977B}, in accordance with IWV-3413.
CV-0944 and CV-0977B will be stroke tested each quarter during performance of procedure
3 Q0-1 to verify that they have traveled to their safety position without measuring stroke time.
Q0-1 will also verify the fail safe testing of CV-0944 and CV-09778 on a quarterly basis. Valve Relief Request 12 has also been corrected to properly reference paragraph IWV-3413 and is included in.
TER ITEM 5.19 The individual listings for the valves identified on Valve Relief Requests 10 and 12, provided in Attachment 5, "Inservice Test Program, Valve Test Table" implies that relief is being requested from the provisions of IWV-3415 concerning Fail Safe Valves.
This is not identified in the text of the Relief Requests and has not been evaluated in this TER (TER Sections 3.2.1 and 3.3.l}.
CPCo Response EGAD-EP-01, "Valve Table" has been revised to remove the reference to Relief Requests 10 & 12 for fail safe testing of CV-0884, CV-0885, CV-0944 and CV-09778.
Fail safe testing for these valves is performed in accordance with the test listed in the valve table. Therefore, a relief request is not needed for fail safe testing of these valves.
TER ITEM 5. 20 The licensee has not provided justification for not full-stroke exercising the component cooling water check valves, CK-CC401 and 402, with flow or verifying closure capability.
The licensee should test these valves in accordance with the Code or revise and resubmit the relief request.
Additionally, the Baseline Data section of Valve Relief Request 13 incorrectly classifies the check valves as Category B, which does not agree with the other sections of this relief request, or the Attachments.
The first sentence of this section is also incomplete as submitted (TER Section 3.3.2).
CPCo Response Valve Relief Request 13 has been deleted.
Full flow testing of CK-CC401 and CK-CC402 is performed via Technical Specification Surveillance Procedure Q0-16, Q0-19 and Q0-20, "lnservice Test Procedures - Cont Spray, HPSI, LPSI Pumps." A recently completed technical review has determined that these valves are not required to close to fulfill their safety function.
Therefore, verifying closure capability is not required.
4 TER ITEM 5.22 It is recommended that relief be denied for the pressurizer PORVs.
The licensee has not provided sufficient justification in Valve Relief Request 15 for not specifying maximum limiting stroke times and performing corrective action upon exceeding these limits.
The licensee should perform tests in accordance with the Code.
Additionally, the licensee has not specified a fail-safe test in Attachment 5.
Based on the FSAR, it appears that the valves have a fail-safe function (TER Section 3.4.1).
CPCo Response Technical Specification Surveillance Procedure Q0-6 has been revised to incorporate a 2-second limiting stroke time for the PORVs.
Q0-6 also incorporates fail safe testing for the PORVs.
As a result, Relief Request 15 has been deleted and Cold Shutdown Testing Basis Number 22 has been revised to mention the 2-second limiting stroke time applied to the PORVs and is included in Attachment 2.
TER ITEM 5.28 It is recommended that generic relief from the requirements of ASME Section XI, paragraph IWV-34ll{b) and 3523 be denied for valves in flowpaths [not]
addressed by the Technical Specifications (Valve Relief Request 22).
The licensee may request specific relief {TER Section 3.8.1).
NOTE: We assume the word "not" in brackets above was mistakenly omitted from the original TER 5.28.
We have inserted the word "not" as noted above and have responded as if the word appeared in the SER.
CPCo Response Relief Request 22 has been revised to specify that it applies only to those valves whose flow paths are covered by Chapter 3 of the Palisades Technical Specifications. The revised relief request is included in Attachment 2.
TER ITEM 5.31 Relief has been recommended for full-stroke exercising the service water pumps' discharge check valves, provided that all the criteria in Generic Letter 89-04 are met.
It is recommended that relief from reverse flow testing be denied.
The licensee should perform this testing in accordance with the Code requirements.
Additionally, the Baseline Data and Acceptance Criteria provided in Valve Relief Request 27 refers to the check valves described in Valve Relief Request 26.
This relief request should be revised, as appropriate {TER Section 3.2.3).
5 CPCo Response The NRC has granted relief to allow disassembly and inspection of these check valves in lieu of full flow testing. These check valves are currently in the disassembly and inspection program.
Valve Relief Request 27 has been revised to delete that portion which covers reverse flow testing the service water pumps discharge check valves (CK-SW401, CK-SW402 and CK-SW403).
Reverse flow testing is now accomplished via Technical Specification Surveillance Procedure Q0-14, "lnservice Test Procedure - Service Water Pumps," by verifying that pump shaft rotation is not noted for each service water pumps check valve while its pump is in standby and the other pumps are operational. The revised relief request number 27 is included in Attachment 2.
We have reviewed the comment concerning Valve Relief Request 27 and its reference to check valves described in Valve Relief Request 26, as well as TER Section 3.2.3 and the June 28, 1991 IST program submittal. Since the June 28, 1991 IST program submittal shows that Valve Relief Request number 26 has been deleted and we can find no discussion of this referenced problem in TER Section 3.2.3, we cannot determine the basis for this comment.
The Valve Relief Request number 27 acceptance criteria section has, however, been revised to address the intent of the comment.
ATTACHMENT 2 Consumers Power Company Palisades Plant Docket 50-255 INSERVICE TESTING (IST) PROGRAM RELIEF REQUESTS, GENERIC LETTER 89-04 (TAC NO. M81064)
ADDITIONAL INFORMATION REVISED RELIEF REQUESTS PRR-4, VRR-12, VRR-22, VRR-27 AND COLD SHUTDOWN TESTING BASIS 22 December 29, 1992 11 Pages
SYSTEMS:
PUMPS:
CLASS:
FUNCTION:
RELIEF REQUEST BASIS NUMBER 4 Auxiliary Feedwater Boric Acid Charging Component Cooling Water Containment Spray High Pressure Safety Injection Low Pressure Safety Injection Service Water Auxiliary Feedwater Pumps (P-8A, P-8B, P-8C)
Boric Acid Pumps (P-56A, P-56B)
Charging Pump (P-55A, P-55B, P55C)
Component Cooling Water Pumps (P-52A, P-52B, P-52C)
Containment Spray Pumps (P-54A, P-54B, P-54C)
High Pressure Safety Injection Pumps (P-66Ai P-66B)
Low Pressure Safety Injection Pumps (P-67A, P-678)
Service Water Pumps (P-7A, P-78, P-7C)
Class 2 and 3 Proc No EM-09-04
. Attachment 5 Revision 15 Page 6 of 13 The safety-related Code pumps listed above perform a specific function in shutting down the reactor or mitigating the consequences of an accident as defined in the Palisades Nuclear Plant UFSAR.
TEST REQUIREMENT:
Measurement and recording of pump bearing vibration amplitude in "peak-peak mils" in accordance with IWP-4500 and Table IWP-3100-2.
i RELIEF REQUEST BASIS NUMBER 4 Proc No "EM-09-04 Revision 15 Page 7 of 13 BASIS FOR RELIEF:
Relief is requested from the requirements of ASME Section XI, Subsection IWP, Article IWP-4500 and Table IWP-3100.2.
Palisades has reviewed the requirements of Sub~ection IWP against those in Part 6 of the OMa-1988 Addenda to OM-1987 (Part 6) for pump vibration testing and prefers to implement the more current requirements found in Part 6.
CPCo believes that alternate rules in Part 6 provide an acceptable level of quality and safety as is reqlfired by 10CFR50.55a(a)(3)(i). This is best demonstrated by the NRC's approval of the 1989 Edition of ASME Section XI (ref: 10CFR50.55a(b)(2) and 10CFR50.55a(b)(2)(viii). The 1989 Edition of ASME Section XI replaced the rules of IWP with those of ANSI/ASME OM (Part 6).
The vibration requirements of Part 6 will be applied with one exception.
An analysis of previous pump test results found that the vibration limits in Ta~le 3a of Part 6 are acceptable for most pumps at Palisades. However, the pumps discussed below were found to regularly exceed the > 0.325 in/sec" Alert Range Limit when they were known to be operating acceptably. Analysis of this data against a> 0.325 in/sec" Part 6 Alert Range Limits yield the following results:
P-54A -
Five of the last six tests would have been in the alert range.
P-548 P-54C The last six tests would have been in the alert range.
The last six tests would have been in the alert range.
P-67A -
Four of the last si~ tests would have been in the alert range.
P-678 -
Three of the last six tests would have approached the alert range.
As shown above, application of this alert limit would inappropriately require these pumps be regularly pl aced on Alert and their test-frequency doubled.
This additional testing burden would not be warranted based on the pumps history of acceptable performance at these vibration levels and could lead to pump degradation.
Furthermore, no benefit can be expected from this additional testing. Therefore, in accordance with 10CFR50.55a(a)(3)(ii),
implementation of the "> 0.325 in/sec" Alert Range Limit for these specific pumps represents an undue hardship without a compensating increased in quality or safety. These pumps cannot meet this requirement because they are tested at low flow rates through a mini recirc line.
This conclusion is supported by the fact that when the containment spray pumps are tested at higher flow rates during cold shutdowns per Tech Spec procedure Q0-10, the vibration levels are less than half of the vibration levels recorded when the pumps are tested during mini recirc. Also, vibration levels recorded during special test T-261, LPSI Pump Performance Test, indicated that vibration levels recorded at design flow rates were less than half the vibration recorded when the pumps are tested during mini recirc.
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ALTERNATE TESTING:
RELIEF REQUEST BASIS NUMBER 4 Proc No EM-09-04 Revision 15 Page 8 of 13 CPCo will implement the Part 6 of the OMa-1988 Addenda to the OM-1987 Edition for pump vibration testing with the following exception.
The > 0.325 in/sec" Alert Limit will be replaced with the limits listed below.
Note that the
> 2.5V to 6V Alert Range will be maintained.
In addition, the > 0.70 in/sec" Required Action Limit will be replaced with the limits listed below.
Alert Limit Required Action Limit Containment Spray Pump (P-54A)
>0.75 in/sec
>1.20 in/sec Containment Spray Pump (P-548)
>1.00 in/sec
>1.50 in/sec Containment Spray Pump (P-54C)
>0.85 in/sec
>1.30 in/sec Low Pressure Injection Pump (P-67A)
>0.70 in/sec
>1.00 in/sec Low Pressure Injection Pump (P-678)
>0.70 in/sec
>1.00 in/sec
RELIEF REQUEST BASIS NUMBER 12 Proc No EM-09-02 Revision 14 Page 25 of 52 SYSTEM:
Component Cooling (M-209-3)
VALVES:
CV-0944, CV-09778 CATEGORY:
FUNCTION:
8 CLASS: 3 These valves Isolate Component Cooling Water to the Radioactive Waste Evaporators on a Safety Injection Signal (SIS).
TEST REQUIREMENT:
IWV-3413; Power Operated Valves - stroke timing.
BASIS FOR RELIEF:
CV-0944 and CV-09778 are normally open valves which close on SIS.
There are no position switches to locally or remotely stroke the CV's.
The SIS test is manpower intensive and would be difficult to coordinate accurate stroke timing..
Relief is requested from the timing requirement of IWV~3414 or CV-0944 and CV-09778.
ALTERNATIVE TESTING:
CV-0944 and CV-09778 are normally open valves which close on an SIS.
These valves can only be actuated via an SIS since there is no means of manually positioning these valves.
The SIS is testeq once each quarter during performance of Technical Specification Surveillance Procedure Q0-1, "Safety Injection Signal." Stroke time coordination of these valves would impose a hardship during Q0-1 for the following reasons:
- 1.
Q0-1 is manpower intensive and involves blocking or bypassing several automatic actuations and must, therefore, be performed in as little time as possible because it places the plant in an abnormal operating condition.
- 2.
The SIS signal is initiated from the Control Room, however, position indication for CV-0944 and CV-09778 is located at remote panel C-105. Coordination between Control Room activities and
.C-105 would be difficult since a dedicated operator would need to be positioned at C-105 with a stopwatch. Starting the stopwatch would be manual based on a verbal signal from the Control Room, resulting in an additional reaction time error over and above that introduced by the Control Room Operator.
As a result, obtaining a consistent stroke time basis suitable for meaningful trending would be near impossible.
The information obtained would be of limited use, due to the anticipated wide range of scatter of the data.
RELIEF REQUEST BASIS NUMBER 12 (Continued)
Proc No EM-09-02 Revision 14 Page 26 of 52 The portion of the component cooling water system isolated by these two valves is a closed loop. Therefore, it would require failure of both of these valves*to close in order to maintain cooling water flow to the Radioactive Waste Evaporators.
Such an occurrence would constitute a multiple active failure which is not required to be considered in the plant's safety analysis.
Based on the above stated reasons and in accordance with 10CFR50.55(a}(3}(II}, relief is requested from the stroke timing requirements of IWV-3413 since compliance with the code requirements would result in hardship without a compensating increase in the level of quality and safety.
ALTERNATIVE TESTING:
CV-0944 and CV-09778 will be stroke tested each quarter during performance of Q0-1.
Q0-1 will verify that CV-0944 and CV-09778 have traveled to their safety position without measuring stroke time.
- Q0-1 will also verify the fail safe capability of CV-0944 and CV-09778 on a quarterly basis.
QUALIFICATION PROGRAM:
None INSTRUMENTATION DESCRIPTION:
The instruments used are identified' in the test document.
Each instrument used to verify adherence to acceptance criteria is maintained in accordance with Palisades Administrative Procedures.
Each instrument is further identified on the Equipment Data Base as "Q" or "B" in the "X" field of the Q-List Int~rpretation.
BASELINE DATA:
RELIEF REQUEST. BASIS NUMBER 12 (Continued)
Pree No EM-09-02 Revision 14 Page 27 of 52 Testing per Q0-1 verifies the subject valves will travel to the close position. This is considered adequate for the following reasons:
- 1.
The valves are testing in the mode in which they would be called upon to mitigate an accident.
- 2.
It would require failure of both of these valves to close in order to maintain cooling water flow to the Radioactive Waste Evaporators, such an occurrence would constitute a multiple active failure which is not required to be considered in the plant's safety analysis.
Based on statements 1 and 2 above, testing per Q0-1 is sufficient to assure the ability of these valves to close.
ACCEPTANCE CRITERIA:
Verification of closure during the performance of Q0-1 for valves CV-0944 and CV-09778 constitutes an acceptable test.
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I RELIEF REQUEST BASIS NUMBER 22 SYSTEM:
Those addressed in Chapter 3 of Technical Specifications VALVES:
Those in flow paths addressed in Chapter 3 of Technical Specifications CATEGORY:
As Applicable CLASS: All FUNCTION:
As Applicable TEST REQUIREMENT:
Proc No EM-09-02 Revision 14 Page 44 of 52 ASME Section XI (IWV-3417(b) and IWV-3523) states that when corrective action is required as a result of testing, the condition must be corrected within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the valve shall be declared inoperative.
In the event of testing during cold shutdown, condition shall be corrected prior to start-up.
BASIS FOR RELIEF:
The Palisades Nuclear Plant Technical Specification limiting conditions for operations, and ASME Section XI, provide the controls by which valves and systems are declared inoperative. Chapter 3, Palisades Technical Specifications, also control entry into various operational conditions, which is generally more restrictive than the ASHE Code,Section XI.
Failure to meet Section XI testing criteria should not, therefore, preclude plant start-up with that particular component inoperative, nor should the declaration of component or system inoperability be extended to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Plant safety is assured by adherence to Palisades Technical Specifications.
ALTERNATIVE TESTING:
For those valves in flow paths addressed in Chapter 3 of Palisades Technical Specifications, the ability to declare component or inoperable, and conduct plant start-up, shall be governed by Palisades Technical Specifications and not by ASHE Section XI, IWV-3417(b) and IWV-3523.
RELIEF REQUEST BASIS NUMBER 27 Proc No EM-09-02 Revision 14 Page 51 of 52 SYSTEM:
Service Water System (M-213)
VALVES:
CK-SW401, CK-SW402., CK-SW403 CATEGORY:
c CLASS: 3 FUNCTION:
- 1.
Prevent back flow of service water through service water pumps.
- 2.
Provide a flow path from the service water pumps to the plant.
TEST REQUIREMENT:
- 1.
IWV-3521; Test Frequency - Exercise at least once every three months.
- 2.
IWV-3522; Exercising Procedure - Exercise to the fully open and closed position.
BASIS FOR RELIEF:
Full flow exercising these check valves to the open position requires knowledge of the individual pump flow rates.
Individual pump units do not have installed flow indicators and piping configuration will not allow an installation of indicators which meet Code requirements.
ALTERNATIVE TESTING:
These check valves are disassembled and inspected (including a manual full-stroke exercise) in accordance with Engineering Manual Procedure EM-28-02, "Preventative Maintenance Program for Check Valves." This method is in compliance with Generic Letter 89~04.
QUALIFICATION PROGRAM:
None INSTRUMENTATION DESCRIPTION:
The instruments used are identified in the test document.
Each instrument used to verify adherence to acceptance criteria is maintained in accordance with Palisades Administrative Procedures.
Each instrument is further identified on.the Equipment Data Base as "Q" or "B" in the "X" field of the Q-List Interpretation..
BASELINE DATA:
None
ACCEPTANCE CRITERIA:
RELIEF REQUEST BASIS NUMBER 27 (Continued)
Proc No EM-09-02 Revision 14 Page 52 of 52 At each disassembly the valves are manually exercised to verify full-stroke capability.
Also~ the disassembled valve is inspected to ensure the internals are structurally sound {no loose or corroded parts).
Check valves closure capability is performed quarterly via Q0-14 by verifying that no pump shaft rotation is noted when the pump is not running.
COLD SHUTDOWN TESTING BASIS NUMBER 22 Proc No EM-09-02 Revision 14
- Page 25 of 38 SYSTEM:
Primary Coolant System (M-201-2}
VALVES:
PRV-10428 and PRV-10438 CATEGORY:
8 CLASS: 1 FUNCTION:
. The power operated relief valves (PORV's) provide primary system overpressure protection from (1) a charging/letdown imbalance, (2) the start of a high pressure safety injection (HPSI) pump and (3) initiation of forced circulation in the PCS when the steam generator temperature is higher than the PCS temperature.
Analysis shows that when three charging pumps are operating and letdown is isolated and a spurious HPSI occurs, the PORV setpoints.
ensures that 10CFR50, Ap~endix G pressure limits will not be exceeded.
Above 430° F, the pressurizer safety valves prevent 10CFR50, Appendix G limits from being exceeded by a charging/letdown imbalance.
The requirement that steam generator temperature be less than or equal to PCS temperature when forced circulation is initiated in the PCS ensures that an energy addition caused by heat transferred from a secondary system to the PCS will not occur. This requirement applies only to the initiation of forced circulation (the start of the first primary coolant pump) with one or more of the PCS cold leg temperatures less than 450° F.
Requiring the PORV's to be operable when the shutdown cooling system is not isolated (M0-3015 and M0-3016 open) from the PCS ensures that the shutdown cooling system will not be pressurized above its design limits.
TEST REQUIREMENT:
- 1.
IWV-3411; Test Frequency - Exercise at least once every three months.
BASIS:
Opening these valves during power operations creates the possibility of the PCS loss of coolant accident (LOCA) with a single failure of the associated PORV block valve. Also, per Technical Specification 3.1.8.1, the PORV's are not required operable while the Plant is at power operations.
ALTERNATIVE TESTING:
Exercise to the open position per Surveillance Procedure Q0-6 each cold.shutdown, but not necessarily more frequently than once each quarter. Acceptable cold shutdown testing shall be performed by stroke timing the valve to the open position within 2 seconds using the solenoid actuator.
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e VERIFICATION METHOD:
e COLD SHUTDOWN TESTING BASIS NUMBER 22 (Continued)
Proc No EM-09-02 Revision 14 Page 26 of 38 The performance of these valves shall be determined by recording and trending stroke time values in the open and close direction per the instructions of Q0-6.
Valve position is determined by observing the valve position indicating lights located in the Control Room.
Acceptable operation shall be indicated when the valve successfully moves from the closed to the open position within 2 seconds.
CORRECTIVE ACTION:
Should either valve fail stroke testing, corrective action per Procedure Step 5.4.1 shall be taken, and an alternative vent path established per the requirements of Technical Specification 3.1.8.1.
ATTACHMENT 3 Consumers Power Company Palisades Plant Docket 50-255 INSERVICE TESTING (IST) PROGRAM RELIEF REQUESTS, GENERIC LETTER 89-04 {TAC NO. M81064)
ADDITIONAL INFORMATION VELOCITY RANGE HISTORY FOR THE CONTAINMENT SPRAY AND LOW PRESSURE SAFETY INJECTION PUMPS December 29, 1992 5 Pages
CONTAINMENT SPRAY PUMP (P-54A)
Vertical Dir.
Axial Dfr. *,.: * *-_*Horizontal Dir.
PMP *cH #1
- .~
~
}. I,<
PMP 'tH
1~'f ~;1'r "j
'( ~ '~ 'p I
PMP CH #3 Reference Value 0.33 0.18 0.35 Units Date I PS-Peak I PS-Peak I PS-Peak 1991 0.18
-...,......,,... ~.-~ -
- --~* - *-- * -**-a,.3s May 23, 0.33 4.J.-......, *~*
- -**-~*..
August 12, 1991 0.30 0.16
- ~
.1 0.32
- ..1, -.*
__ P_, **
November 12, 1991 0.30 0.16 0.34 January 22, 1992 0.30 0.19 0.31 July 8, 1992 0.37 0.17 0.40 October 21, 1992 0.28 0.16
/'\\
F 0.33
J **
CONTAINMENT SPRAY PUMP (P-548)
Vertical Dir.
.-, Axial* Dir. -** J b o;*HBrizorital Dir.
PMP CH #1 PMP CH #2 PMP CH #3 Reference Value 0.42 0.28 0.48 Units Date I PS-Peak I PS-Peak I~S:Peak May 23, 1991 0.42 0.28
- ---0-1\\48 I
Auqust 12, 1991 0.38 0.27 o.[:4a i
November 13, 1991 0.35 0.28 0:48 January 22, 1992 0.33 0.28 0.43 July 8, 1992 0.34 0.25 0-:36 October 21, 1992 0.36 0.21
'"'"*"'*.... *~Q,!i 3 6
I CONTAINMENT SPRAY PUMP (P-54C)
Vertical Dir.
Axi ~t Di.~,*.. *.;""'~ ~ Horizontal Dir.
- PMP CH #1 PMP CH #2 PMP CH #3 Reference Value 0.27 0.23 0.42 Units Date JPS-Peak JPS-Peak JPS-Peak May 23, 1991 0.27 0.23 0.42 August 12, 1991 0.30 0.19 0.38 November 14, 1991 0.27 0.23 0.38 January 22, 1992 0.31 0.22 0.35 July 9, 1992 0.29 0.21 0.38 October 21, 1992 0.27 0.19 0.38
l
}...,
LOW PRESSURE SAFETY INJECTION PUMP (P-67 A)
Vertical Dir.
Axial Dir.
. ~r."- ~'Horizontal Dir.
PMP CH #1 PMP CH #2 PMP CH #3 Reference Value 0.25 0.14 0.30 Units Date I PS-Peak I PS-Peak I PS-Peak June 5, 1991 0.25 0.14 0.30 Auqust 28, 1991 0.23 0.14 0.36 November 22, 1991 0.21 0.15 0.34 April 11, 1992 0.28 0.15 0.33 July 9, 1992 0.24 0.15 0.30 October 22, 1992 0.30 0.15 0.36
4 LOW PRESSURE SAFETY INJECTION PUMP (P-678)
II";>
Vertical Dir.
Axial Dir.
Horizontal Dir.
PMP CH #1 PMP CH #2 PMP CH #3 Reference Value 0.24 0.16 0.27 Units Date I PS-Peak I PS-Peak I PS-Peak June 5, 1991 0.24 0.16 0.16 Auaust 28, 1991 0.23 0.16 0.28 November 22, 199 0.24 0.16 0.30 April 11, 1992 0.25 0.16 0.26 July 9, 1992 0.23 0.16 0.21 October 22, 1992 0.26 0.15 0.30