ML18065B220
| ML18065B220 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/21/1998 |
| From: | Haskell N CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-NUREG-1482 NUDOCS 9804280073 | |
| Download: ML18065B220 (4) | |
Text
- 1 A CMS Energy Company
- -Palisades Nuclear Plant
- Tel: 616 764 2276 l ** _,.
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U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Covert. Ml 49043 DOCKET 50-255 - LICENSE DPR PALISADES PLANT I
. ; Director, <Licensing SUBMITTAL OF PUMP INSERVICE TESTING RELIEF REQUEST NUMBER 11 Consumers Energy Company has recently determined that a permanently installed flowrate instrument used for lnservice Testing of the Charging Pumps P-55B and P-55C does not meet the full-scale range requirements of the ASME Section XI Code, reference OMa-1988, Part 6. However, that instrument does meet the overall accuracy requirements equivalent to the instruments permitted by the Code. As such, using t_he guidance of NUREG-1482, "Guidelines for lnservice Testing at Nuclear Power Plants,"
Section 5.5.1, the attached Pump Relief Request No. 11 is submitted for approval.
Consumers Energy intends to continue using this instrument for the required pump surveillance tests since the instrument accuracy is at least equivalent to that required by the Code. However, since approval of this relief request is required, we request the approval prior to the next scheduled surveillance test involving this instrument. The next scheduled test date is June 6, 1998.
SUMMARY
OF COMMITMENTS
[.
This letter contains no new commitments and no revisions to existing commitments.
Nathan L. Haskell Director, Licensing CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC
- NRC Resident Inspector - Palisades Attachment
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ATTACHMENT CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 SUBMITTAL OF PUMP INSERVICE TESTING RELIEF REQUEST NUMBER 11 2 Pages
SYSTEM:
PUMP:
CLASS:
FUNCTION:
- PUMP RELIEF REQUEST NUMBER 11 Chemical and Volume Control - Charging P-558 and P-55C (Charging Pumps) 2 These pumps return deionized and filtered reactor coolant to the Primary Coolant System (PCS) at a rate equal to the purification flowrate and the con.trolled bleed-off rate. Upon receiving a safety injection signal, the pumps are started and discharge concentrated boric acid into the PCS.
TEST REQUIREMENT:
OMa-1988 Part 6, Section 4.6.1.2(a) states, "The full-scale range of each analog instrument shall be not greater than three times the reference value."
RELIEF REQUESTED:
Palisades requests relief to use an analog instrument loop with a range that is 3.6 times the flowrate reference value. The instrument loop is permanently installed original plant equipment.
BASIS FOR RELIEF:
Our instrument loop is calibrated to tolerances better than the 2% of full-scale required by OMa-1988 Part 6, Table 1. The combined range and accuracy of the loop yields a reading which is more accurate than the reading from an instrument that meets the Code range requirement. Therefore, this instrument meets the intent of the Code requirements for the actual reading and would yield an acceptable level of quality and safety for the test results.
The flowrate reference value for both P-558 and P-55C is nominally 39.0 gpm (as of March 1998). The maximum allowable range based on this value is 0-117.0 gpm. Our proposed instrument loop has a range of 0-140 gpm which is 3.6 times this reference value. The Code requires an accuracy of +/-2% of full-scale which equates to +/-6% of the reference value (+/-2.34 gpm). Our instrument loop has an accuracy of 1.5% of full-scale 1
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PUMP RELIEF REQUEST NUMBER 11
- or +/-5.4% of the reference value (+/-2.12 gpm). The equipment we are requesting relief for provides more accurate readings than would be provided if the minimum Code requirements for the full-scale range were satisfied.
JUSTIFICATION:
This request is consistent with the NRC guidance in NUREG-1482, Section 5.5.1. In that response, the NRC states, "When the range of a permanently installed analog instrument is greater than 3 times the reference value but the accuracy of the instrument is more conservative than the Code, the staff will grant relief when the combination of the range and accuracy yields a reading at least equivalent to the reading achieved from instruments that meet the Code requirements (i.e., up to +/-6 percent)."
The combined range and accuracy of our instrument loop provides an overall uncertainty better than the minimum Code requirement. Therefore, the intent of the Code is satisfied and the reading afforded by our instrument loop yields an acceptable level of quality and safety for testing.
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