ML18066A333
| ML18066A333 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/24/1998 |
| From: | Haas K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-98-02, GL-98-2, NUDOCS 9812020024 | |
| Download: ML18066A333 (3) | |
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Palisades Nuclear Plant 27780 Blue Star Memorial Highway
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November 24, 1998 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT RESPONSE TO GENERIC LETTER 98-02, LOSS OF REACTOR COOLANT INVENTORY AND ASSOCIATED POTENTIAL FOR LOSS OF EMERGENCY MITIGATION FUNCTIONS WHILE IN A SHUTDOWN CONDITION On May 28, 1998, NRC issued Generic Letter 98-02, entitled, "Loss of Reactor Coolant Inventory and Associated Potential for Loss of Emergency Mitigation Functions While in a Shutdown Condition." This Generic Letter requires each licensee to perform an 1.
1 assessment of whether or not the plant "... emergency core cooling systems include certain design features, such as a common pump suction header, which can render the systems susceptible to common cause failure as a result of events similar to the Wolf Creek RCS draindown event of September 17, 1994". The G~neric Letter specified that the assessment focus may be limited to "~.. surveillance, maintenance, Ao modification, and operational activities at hot shutdown during which it is feasible to 0 I divert RCS fluid to the RWST, resulting in simultaneous draindown of the RCS and voiding in the suction header for the RHR and ECC system pumps". If the assessment reveals that such susceptibility exists, the result of the assessment is required to be reported in writing pursuant to 1 OCFR50.54(f) and 1 OCFR50.4.
In response to the Generic Letter, Palisades has completed an assessment of Safety Injection System design, operating procedures, and surveillance procedures, as well as a review of programmatic controls and performance oversight under 1 OCFR50 Appendix B. The information requested by the Generic Letter is available on site for NRC review.
. 9812020024 981124.7 PDR ADOCK 050002551 P.
PDR:J
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\\l At Palisades the Safety Injection System has two basic operating configurations which provide either the ECCS function or the Shutdown Cooling function. For the purpose of this assessment, the temperature range for "hot shutdown" (mode 4) was assumed to be as defined in the former Standard Technical Specifications (STS) for Combustion Engineering plants (NUREG 0212, Rev 2) and the Palisades Improved Technical Specifications submittal based on the current STS (NUREG 1432) as 300°F> Tav9>200°F. For the temperature range of interest, the ECCS function of the Safety Injection System is not required by Technical Specifications to be operable. This is in apparent contrast to the Generic Letter discussion of Wolf Creek. However, it is possible that valve misalignments could cross connect the two pump suction headers from the Safety Injection and Refueling Water Tank during periods when the ECCS function is required to be operable. While this* should not affect the operability of the ECCS function, cross connecting the suction headers would be inconsistent with the system design basis When the Safety Injection System is aligned into its shutdown cooling configuration (Tavg <300°F), the shutdown cooling pumps are supplied through a common Primary Coolant System drop line and pump suction header. Therefore, it is possible that certain errors could lead to a loss of shutdown cooling flow or depressurization of a hot Primary Coolant System, and that voiding in the shutdown cooling system could result.
The assessment did not reveal major deficiencies in existing controls or procedures, but a number of procedure enhancements have been identified to provide stronger barriers that more specifically address these issues. Follow up actions are planned to implement the identified enhancements.
SUMMARY
OF COMMITMENTS This letter contains no new commitments and no revisions to existing commitments.
I Kurt M. Haas Director, Engineering CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades
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CONSUMERS ENERGY COMPANY To the best of my knowledge, the contents of this letter entitled "RESPONSE TO GENERIC LETTER 98-02, LOSS OF REACTOR COOLANT INVENTORY AND ASSOCIATED POTENTIAL FOR LOSS OF EMERGENCY MITIGATION FUNCTIONS WHILE IN A SHUTDOWN CONDITION", are truthful and complete.
By Kurt M. Haas Director, Engineering Sworn and subscribed to before me this
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Mary Ann Engle, Notary Public Berrien County, Michigan (Acting in Van Buren County, Michigan)
My commission expires February 16, 2000 day of ~
1998.