ML20010G828
| ML20010G828 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/14/1981 |
| From: | Johnson B CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| IEB-80-06, IEB-80-6, NUDOCS 8109220561 | |
| Download: ML20010G828 (24) | |
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Nuclear Licenstng Alnrinsstratur CampHDy Generei Offices: 1946 weet Perneh mood, JockerA MI 49201 e (51717841836 September 14, 1981 P/s\\ d.L @
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MYSpO Mr James G Keppler U
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g Cifice of Inspection and Enforcement ISBf Region III p
US Nuclear Regulatory Commission y
799 Roosevelt Road y
Glen Ellyn, IL 60137 9 Jg y
DOCKET 50-255 -DPP PALISADF.S PLANT -
SUPPLEMENTAL INF9RMATION - IE BULLETIN 80 ENGINEERED SAFETY FEATURE (ESF) RESET CONTROLS IE Bulletin 80-06 dated March 13, 1980 requested Consumers Power Company to determine if all associated safety-related equipment remains in its safety-related mode upon the reset of the emergency safety features actuation signal i
(ESFAS). This list of equipment was provided es Attachment 2 of Consumers l
Power Company letter dated June 23, 1980 and 13 provided as Attachment 1 to this letter.
Duric;g a telephone conversation with the NRC July 7,1981, Consumers 1ower Co9pany was requested to provide justification as to why the emergency safety feature (ESF) equipment which doe
- not remain in the emergency mode upon ESF reset should not be modified. As described in our letter of June 23, 1980, Palisades Plant Emergency Operating Procedure #1 " Reactor Trip" requires that a number of post-trip conditions be established prior to resetting safety injection (these post-trip conditions are listed in Attachment 2).
Our June 23, 1980 letter states that since all of these conditions must t;c met prior ta resetting safety injection, the plant wc91d be in such ; cendition aa to safely secommodate the return of these safety injection components to their normal mode of operation.
6,CP /
In response to the July 7, 1981 request, the list from our June 23, 1980 f' I letter, Attachment I to this letter, was evaluated to assess the impact e..
each of the listed component's response to ESF reset.
Centrary to the posi-tion taken in our June 23, 1980 letter which stated that the plant could safely accommodate the return of these safety injection components to a normal
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mode, this evaluation revealed tbst some of these ccxponents responded to reset in a manner which may be undesirable.
< documents the aforementioned :evgluation and recommends certain procedural.:nodifications which will be implemented to prevent certain ESF components from assuming a normal mode of operation upon ESF reset which could-possibly result in equipment damage. As can be seen in Attachment 3, oc0981-0005a142 8109220561 810914 SEP f 619er PDR ADOCM 05000953 E"
l' Mr Jtmes G Keppler 2
Palisades Plaat September 14, 1981 procedural modifications are planned for the service 9ater valves that supply the ESF room coolers (valves SV0825 & SV0878), the component cooling water valves to shutdown heat exchangers (valves SV0937 & SV0938), the component cooling water valves to the spray pumps' and injection pumps' seal cooling (valves SV0913 & SV0950) and containment spray header isolation valves SV3001 and SV3002.
It is the opinion of the Consumers Power Compary that procedural modifica-tions, in lieu of circuit modifications, are preferred for the following reasons:
1.
The existing circuit logic for these components readily lends itself to procedural supervision and restriction regarding its operational status.
For example, the closure of each of the aforementioned valves can be prevented by sieply placing the control room hand switches for these valves in the open position.
2.
Gy the time that the ESF can be reset, the operators will have had sufficient time to refer to procedures ar.d utilize them fcr plant recovery.
Final.tv, it should be noted that Fans V-36 and V-46 should be removed from the list (Attachment 1).
As can be seen in the attached schematic drawings E-271 and E-222, respectively, both fans remain in their emergency mode upon ESF reset.
Brian D :onnson Senior Licensing Engineer CC Jtrector Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector-Palisades i
oc0981-0005a142
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TONR 57-81 ATTACHMETr i SAFETY-RELATED TQUIletENT THAT DOES EMIN TN THE EFERGENCY MODE UPON ESF RESIT (Page 1 of 2)
I Equipment Equipment.
Emergeney Item #
Designation Description Mode (1)
SV0878 Service Water to ESF Cooler Open (2)
SV03h2 SI Tank Relief Valvo Clos-(3)
E/P 2130 Boric Acid Recire Valve Close (k)
SV03h6 SI fank Relief (alve Cloae (5)
SV0911 Component Cooling Water From Containment Close (6)
SV0910 Component Colling Water To Containment Close (7) 570938 Component Coeling Water To Shutdown Hx Open (8)
SV0825 Service Wats: to ESF Cooler Open (9)
SV1359 Service Water to Non-Critical Items Close (10)
SV3069 SI Tank Leakage Valve Close (11)
SV0950 Component Cooling Water From Seal Cooling Open (12)
SV03kT SI Tank Relief Valve Close (13)
E/P 2136 Boric Acid Becire Valve Close (1k)
SV0338 SI Tank Relief Val're Close
?.15 )
SV0913 Com13nent-Cooling to Seal Cooling Open (16)
SV09hhA Component Cooling Water To Fuel Pool Hx Close (17)
SV0373 Fervice Water From Containment Coolers Open (18)
SV0861 Service Water Fros Containment Coolers Open (19)
SV09hh Component Cooling Water to Rad Waste Evars Close (20)
SV09773 Component Cooling Water to Ras Waste Evaps Close (21) 3V0940 Component Cooling Water From Containment Close (22)
SV0910 Component Cooling Water To Containmer-Close (23)
SV0937 Comoonort Cooling Water to Shutdown Hx
.Open
- (2h)
SV0864 Service Water From Coatainment Coolers Open (25).
SV0913 Component Cooling Water to Sesl Cooling Open f
Faga 2 of 2 Equipment Equipment Energency Item #
Designation Description Mode (26)
SV0950 component cooling Water From Seal Ccoling Open (27)
SV0867 Service Water from containment coolers open (28)
SV0k37A Iodine Removal Tank Discharge Valvt Open (29)
SV3001 containment Spray Discharge Valve Open (30)
SV0h37B Iodine Removs1 Tank Discharge Valve Open (31)
SV3002 containment Spray Discharge Valve Open (32)
SV21M Boric Acid Blender Outlet Valve Close (33)
V-36 control Room Isolation Fan Start (3h)
V-L6 Air Room Pu;ge Fan Trip i
b J
Paga 1 of 1 TONR 57-81 ATIACHMENT 2 POST-REACTOR TRIP CONDITIONS WHICH MUST BE MET IN ORDER TO RESET SAFETY INJECTION PER EMERGENCY OPERATING PROCEDUPI #1
" REACTOR TRIP" (Page 1 of 1) 1.
The reactor is shut down and vill remain shut down.
2.
The hot and cold leg temperatures are at least 50 F subec61ed.
3 The cause of the low pressure condition is known and corrected.
h.
Pressurner pressure is greater than 1700 psia and Is esturning to vormal.
5 Pressurizer level is greater than 20% ard is returning to normal.
6.
T is stable or increasing and is less than Sk5 F.
gyg 4
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r Paga 1 of 6 TONR 57-81 A?rACHMENT 3 JUSTIFICATION JTD/OR REQUIRED MODIFICATION FOR ESF EQUIFMENT WHICR LUGES NOT RINAIN IN THE IMERGENCY MODE UyN ESF RESET Position Drawing #
Component Upon (Drawing Ite= ##
Component #
D*seri;: tion ESF Reset Location)**
i 8
SV0821 Service Water to ESF Room Closed M-208 (C/3)
Coolers 1
SV0878 Service Water to EEF Room Closed M-200 (C/3)
Coolers Reauirea Modification:
Although the containment sprny (CS) pu=ps and the low pressure safety injection (IPSI) pu=ps may be shut down by the ti=e the SSF signal can be reset, the high prescure safety injection (HPSI) pu=ps vill most likely be in operation providing lorc-tem core cooling. The operation of these pumps vill significantly contri-bute to the heat input to the ESF roon. Other heat additions to the room vill occur from motor copper losses and safety injection piping carrying hot contain-ment su=p water during the recirculation phase.
According to the Consu=ers Power Co=pany's October 1980 Environmental Qualifi-estion of Safety-Related Electrical Equipment report, the expected te=perature for the ESF room during shutdown in 900F. It should be noted that the basis for this te=perature is the set point of the room ther=ostats. These thermo-stats are presently set to automatically start the ESF room cooler fans at a te=perature between 850F and 88 F.
Accordingly, the Consumers Power Company vill modify existing operating proce-dures to prevent the cubject va'ves, if required, from closing upon E5F reset.
As can be seen in Drcvings E-219-1 & 3, the existing circuit logie vill allow procedural modification to prevent valve closure. As can be seen, resetting safety injection vill not close the valves if either or both of the hand switches (eg, HS0878 A & B) are in the open position. Therefore, a procedural requirement can be added to place these hand switches (located in the control room) in the open pcsition, if required, prior to ESF recet.
F e
Paga 2 of 6 TONR 57-81 Position Drawing #
Attachmeat 1 Component Upon (Drawing
' tem #*
Component #
Description ESF Reset Locatien)**
18 SV0861 Service Water From Contain-Closed M-208 (C/6) ment Coolers 24 SV086h Service Water From Contain-Closed M-208 (A/6) ment Coolers 27 SV0867 Service Water From Contain-Closed M-208 (C/8) ment Coolers 17 SVOST3 Service Water From Contain-Clesed M-208 (A/7.
ment u olers Justification Requiring that Attachment 2 post-trip conditions #2, k and 5 are met prior to ESF reset provides reasonable assurance that no significant primary coalr.nt system energy release to the reactor building is occuring. There-fore, when the post-trip conditions are met, it vili not be necessary for the coolers to be in service to provide reactor building pressure reduction and subsequent reduction in leakage of airborne radioactivity.
It is,therefore, allovable that these valves close upon ESF reset.
It should be noted that safety injection reset cannot be accomplished with a standing containment high pressure (CHP) condition in the first placa. This fact alone ensures that service water to the containment coolers vill not be disrupted during a condition requiring these coolers to perfer= their safety-related function.
Position Drawing #
At+ach=ent 1 Component Upon (Drawing Item #*
Cc=ponent #
Description ESF Reset Location)**
9 SV1359 Service Water Tc Non-Critical Open M-213 (E/7)
Items Justif(j3 tion:
Whenever post-trip conditions are such that the ESF signal can be reset (see Attach =ent 2), this valve is opened to provide service water for cooling non-critical ite=s such as the turbine lube oil coolers, the turbine EH oil coolers and the condensate pumps cooling, among others. Table 9-1 of the FSAR shows that the capacity of the service water system (SWS) would not be exceeded in the event that the non-critical items were valved into tne SWS while all of the critical items were still operating.
As can be seen in the table, a total shutdown cooling flow of 15,565 gpm (critical items) and a total non-critien1 items flow of 6110 gpm would result in a total SWS flow of 21,675 gpm. Under these vorst-case conditions, the SWS vould not be overdutied since it is rated at 24,000 gpm (8000 gpm/pu=p).
In addition, there may be a need to establish the availability of the SWS to the non< critical items in a timely manner. An example vould be the necessity of providing cooling water to the condensate pump in the event that this pump is needed as an alternate feed to the steam generators.
Therefore, it is desirable that this valve open upon ESF reset.
I Pag 2 3 or 6 TONR 57-81 Position Drawing #
Component Upen (Drawing Ite= ##
Ce:ponent #
Description ESF Reset Location)**
6 (22)
SV0910 Component Cooling Water To Open M-209 (E/5)
Contain=ent 5
SV0911 Component Cooling Water From Open M-209 (A/6)
Cont ainment 21 SV0940 Co=ponent Cooling Water From Open M-209 (A/5)
Contain=ent Justification :
Upon satisfying the required post-trip conditions (see Attach =ent 2) and resettirg the ESF signal, it is prefarred that the subject valves assu=e an open position. The reason for this preference is the need to establish cooling flow to the primary coolant pu=ps and to the control rod drive
=echanis=s to protect the seals.
As can be seen in FSAR Table 9-6, reopening the component cooling vatir (CCW) valves to and from the containment upon ESF reset vill not overduty the CCW syste= nor starve the leads already in service. As an example of a worst-case condition, the total CCW syster flev rate of 10,139 gp= for the condition of "2h hours after initiation of shutdova'"can be added to the in-containment CCW loads of 53h gp= to yield a total CCW load of 10,673 gpe, Tae addition of the in-containment CCW loads vill not over-duty the CCW system since it it, rated at 18,000 gpm (6,000 gp:/ psp).
It should be noted that Ite= 22 is a duplication of Item 6 in Attach =ent 1.
Position Drawing #
Attach =ent 1 Co=ponent Upon (Drawing Ite= #*
Co=penentJ[
Description ESF Reset Location)**
23 Svo937 Component Cooling Water to closed M-209 (H/3)
Shutdown Hx 7
SV0938 Component cooling Water +o closed M-209 (F/3)
Shutdown Ex Recuired Modification:
As described in the " Justification and Eequired Medifications" discussion for the CCW v ives that provide seal cooling (Valves SV0973 and SV0950),
the containment sprwy pumps may be in operation at the time of ESF reset.
These pumps may be providing containment cooling by circulating contain-
=ent su=p water through the shutdown heat exchangers. Therefore, the CCW valves to these heat exchangers may have to remain open upon ESF reset.
Since the valves' control logic is similar to that for Valves SV0825 and SV0878, modifications to existing operating procedures will be =ade to ensure that, if required, these valves do not close upon ESF reset (refer to Drawings E-239-1 12 for Valves SV0937 and SV9038 control logic).
As in the case of Valves SV0825 & SV0878, cperating procedures vill be modified t) place the valve hand switches (located in the control room) in the open position, if required, prior to ESF reset.
r-Paga h of 6 TONR 57-81 Position Drawing #
Co=ponent Upon (Drawing Item #*
Component #
Description ESF Reset Locatien)**
15 (25)
Svo913 Component cooling water To Closed M-209 (D/3)
Seal Cooling 11 (26)
SV0950 ce=ponent cooling Water To closed M-209 (c/5)
Seal Cooling Required Mcdification:
Drawing M-209 shows that the above valves, when closed, serve to isolate seal cooling flow to the LPSI, HPST and CS pumps.
Closing th'ese valves upon
=eeting the post-trip conditions in Attachment 2 and resetting the ESF signal is acceptable since the CS pumps will most likely be shut down (a standing CHP condition vill not allow the.ESF signal to be reset in the first place) as vill the LPSI pumps which receive an auto trip upon switchover from injection to recirculation. Althougn the HPSI pu=ps may still be running, FSAR, Paragraph 6.1.2.2(c) states that HPSI pumps "are designed for the thermal transient conditions of 40 F to 300 F in five seconds". FSAR figure lh.18-9 shows that the peak temperature of the liquid inside containment only reaches approximately 268 F in approxi=ately 5 seconds and the containment st. p is at least 30 F subcooled at that time. The FSAR uther states that the HPSI pu=p seals "are designed for operation at 300{F, but are provided with cooling to extend seal life' in a similar =anner to the low pressure pu=ps".
Since the CS pumps do not feature an auto trip signal, procedural =odifi-cations are necessary to ensure that either of the following is verified prior to ESF reset: 1) the CS pu=ps are shut down or 2) provisions have been =ade to prevent the seal cooling valves and the containment spray head.er isolation valves from c1 cling upon ESF reset (refer to the "Just-ification and Required Modifications" discussion for V&lves SV3001 and SV3002). It should be noted that for each of these valves (SV0913, SV0950, SV3001 and SV3002) procedural modifications would be implemented to prevent closure upon reset by stating that, if required, the hand switches for these valves should be placed in the open Iosition. Sche =atic Drawings E-237 and E-239-2 reveal the circuit logics.
It should be noted that Items 25 and 2f are duplicates of Items 15 and 11, respectively (see Attachment 1).
Position Drawing #
Component Upon (Drawing Ite= ##
Cc=ponent #
Description ESF Reset Location)**
14 SV0338 Safety In.jection Tank Relier Open M-203 (D/h) '
Valve 2
SV03h2 Safety Injection Tank Relief Open M-203 (D/T)
Valve h
SV0346 Safety Injection Tank Relier Open M-203 (D/6)
Valve
Page 5 of 6 TONR H-81 12 SV03kT Safety Injection Tank Relief Ope-M-203 (D/5)
Valve 10 SV3069 Safety Injection Tank Leakage Open M-203 (D/8) l Valve Justi11 caw Sn:
Upon meeting the post-trip conditions as ite=ized in Attach =ent 2 and resetting the ESF signal, the desired action of these valves is to travel open. Opening Valves SV0338, 03h2, 03h6 and 03kT will provide instru=ent air to control Valves CV3038, 3042, 30h6 and 3Ch7, respectively. This air enables the control valves to regulate the pressure between the check valves at the outlet of the SI tanke to prevent these check valves from leaking and allowing primary coulant system pressure from reaching tM tanks. Proper regulation ensures that the tanks, designed for pressures less than the primary coolant system pressure, are not over-pressurized. Proper regulation also ensures that the SI tank contents (if still available) are not diluted with pci=ary coolant water.
It is also desired that Valve SV3069 open upon ESF reset since it serves as the co==on SI tank leakage path to the primary system drain tank.
The proper operatien of Valves CV3038, 'ch2, 30h6 and 30h7 is dependent on SV3069 opening.
Position Drawing #
Attach =ent 1 Couponent Upon (Drawing Ite= #*
Co=cenent #
Description ESF Reset Location)**
3 E/P2130 Boric Acid Fu=p Recire Valve Open M-202 (E/2) 12 E/P2136 Boric Acid Pu=p Recire Valve Open M-202 (E/3)
Justification:
Allowing these valves to automatically open upon ESF reset is acceptable since the boric acid pu=ps vill provide adequate flow for shutdown con-ditions which would prevail after the post-trip conditions (as listed in Attach =ent 2) are =et even with the recirculation valves open. It should be noted that. Drawing M-202 shows that these valves are normally open and close only upon SIS actuation.
Position Drawing #
Attach =ent 1 Co=ponent Upon
(. Drawing Ite= #*
Co=tonent #
Descriptien ESF Reset Locatien)**
28 Svoh37A Iodine Re= oval Tank Deh Valve Closed M-20h (F/2) 30 SVoh37B Iodine Removal Tank Deh Valve Closed M-20h (F/2)
Pago 6 of 6 TONR 57-81 Justification:
According to FSAR, Paragraph 6.h.2.1, the iodine re= oval tank 's used to provide '.n initial pH of approximately 7 in the combined quanti les of SIRW tank water, primary syste= ve.ter and safety injection tank water.
A second tank, the iodine reyoval make-up tank, is available for continued pH control during the recirculation phase of the DBA. Therefore, allowing the above iodine removal tank valves to close upon ESF reset is appropriate since the iodine removal tank vill have already performed its function.
Position Drawing #
Attach =ent 1 Component Upon (Drawing Ite= ##
Component #
Description ESF Reset Icention)**
29 SV3001 Containment Spray Syste=
Closed M-203 (H/3)
Discharge Valve 31 SV3002 Containment Spray Syste=
Closed M-203 (G/3)
Discharge Valve Required Modification:
Allowing these valves to close upon resetting the ESF signal is acceptable since the need for containment spray at this time vill =ost likely not be present. In fact, a standing CHP condition vill not allow the ESF signal to be reset in the first place. However, to ensure that the discharge path will not be removed from the pu=ps for any appreciable a= cunt of time should the pu=ps be running after the CHP has cleared (it should be noted that the pu=ps do not auto trip upon re= oval of the CHP signal),
operating procedures vill be modified as described in the " Justification and Required Modifications" discussion for Valves SV0913 and SV0950.
Position Drawing #
Attach =ent 1 Component Upon (Drawing Ite Component #
Description ESF Reset Location)**
I 32 SV2155 CVCS Make-up Valve Open M-202 (D/6)
Justification:
Since adjustments in boren concentration may be necessary during long-term shutdown, allowing this valve to open upon meeting the post-trip conditions of Attachment 2 and resetting the ESF signal is acc 9 table.
- Items are grouped according to similarity.
- Referenced drawin6s are attached.
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