ML20041C311
| ML20041C311 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 01/22/1982 |
| From: | Vanderbeek R EG&G, INC. |
| To: | NRC |
| Shared Package | |
| ML20041C310 | List: |
| References | |
| TASK-06-07.A3, TASK-6-7.A3, TASK-RR 0040J, 40J, NUDOCS 8203010145 | |
| Download: ML20041C311 (9) | |
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SYSTEMATIC E7ALUATION ?ROGRAM TOPIC VI-7. A.3 ECCS ACTdATION SYSTEM 3IG ROCX ?0 INT Cocket No. 50-155 January 1982 R. VancerSeek EG&G Idano, Inc.
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SYSTEMATIC EVALUAT*0N PROGRAM TOPIC VI-7.A.3 ECCS ACTUATION SYSTEM 3IG ROCK ?OINT
1.0 INTRODUCTION
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The cojective,of :nis review is to determine if all Emergency Core i
Cocling System (ECCS) comocnents, including pumcs ano valves, are included in c:moonent and system ests, if the scoce and frecuency of ;eriodic test-ing are identified, and if tne test program meets current. licensing
- riteria.
The systems included in the ECCS are the Core Spray and Core Spray Recirculation System.
2.0 CRITERIA i.
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General Design Criterion 37 (GDC 37), " Testing of Emergency Core Cool-ing Systems," recuireo that:
The ECCS be designea to permit appropriate cericcic pressure and func-tional testing to assure the operability of the system as a whole anc to verify, uncer conditions as close to cesign as practical, the per-formance of the #ull operational sequence that brings the -system into operation, including operation of acplicable porticns of the protection system, the transfer bet, ween normal anc emergency powgr sources, and i
- the operation of the associated coo'ing. vater system.-
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3 ranch Technical ?osition ICSB 25, "Guicance for tne Interpretation of GDC 37 for Testing the Coerability of tne Emergency Core Cooling System as l
a Whole," states that:
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All ECCS pumps snculc te incluced in the system test.3 f
Regulatory Guide 1.22, " Periodic Testing of the Protection System Actu-ation Functions," states, in Section D.l.a, that:
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The periodic tests should duplicate, as closely as practicable, the l
performance that is reouired of the acutation oevices in tne event of l
an accident.'
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i Standard Review Plan, Section 7.1, Appendix 3, "Guicance for Evalua-tion of Conformance to IEEE STD 279," states,* in Section 11, that:
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Periodic testing should duplicate, as closely 'as practical, the over-all performance recuired of the crotection system. The test should confirm operacility of both the automatic and manual circuitry. The capability snould oe.proviced to permit testing curing ' power operation.
When this capability can only be achieved by overlapping tests, the test scheme must be such_that the tests do, in f act, overlap frcm one test segment to another.3 Regulatory Guide 1.22 states, in Section D.{, that:
i Where actuated equipment is not tested curing reactor operation, it 1
sr.ould be shown :nat:
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There is no cractical system design that aculd permit operation of the acutated ecuipment without adver.sely affecting the safety 4
or coerability of the plant.
2.
The probability that the crotection system will. f ail to initiate 1
j tne coeration of the actuatec ecuipment is, and can be Maintained, i
acceptably low withcut testing the acutated ecui: ment curing i
reactor coeration.
3.
The actuatec 9quipment can be Outinely tested unen the reactor j
is snut down.'
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3.0 CORE SPRAY SYSTEM i
2.1 Descriotion.
The Core Spray System is :esignec to trovide reac-tor ccoling in the event of a loss of coolant accicent (LOCA). The Core i
Soray System :tnsists of two parallel lines which run from the station fire header in the turoine building thrcugn the reactor centainment and into the reacter vessel.
A spray nozzle 's :rovided for cne of tne lines and a i
scray rin'g is utilized for the other line, insice the vessei ano accut six l
feet accve tne core, to scray water directly onto the fuei assemolies in a
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pattern wnich provides adequate cooling.
Ficw to the Core Spray system in the initial stages of a LOCA is proviced by two statien fire pumps (one f
electric anc cne diesel driven) which draw nater from Lake Michigan.
The long-term water supply to the Core Soray System is :revided by the Core v
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,c Sor ay Recircul ation System.
The Ccre Soray System is automatically actuated upcn icw reactor water level and Icw reactor primary pressure.
3.2 Evaluation.
The Big Rocx Point Plant Technical Soecification
-equire the motor coerated valves in the direct ficw path into the reactor vessel to ce acutated monthly by a manual remote to verify correct action of v alve occurs.
And on a refueling cutage each valve of the Core Spray Sfstem in the flow pa:n are actuated manually and autcmatically witn water
- 1cw normally blocked.
The pumos suoplying the water to the C0re Scray System are cart Of the Plan Fire Water Sys tem.
The pumos are started and operated once every 31 days.
The Ccre Spray Sys;em is not :estec from the automatic anc manual acutation devices througn t'o the estaclishement of ficw through to the ccre soray neader and soray ring during reac:cr caeration, as specified by Stancarc 3.cView Plan Section 7.1, Appenaix 3, Section 11.
Because of the f act that actuation of tne Core Scray System would result in the injection of water from Lake Michigan into tne reac:cr, testing curing reacter opera-tien is cearea impractical.
However, although the sysem and ccmconents are tested periodically (seme anile the reacter is operating), there is no es tablisned requirement in the technical specifications for a periodic systems integrated tes to determine ne coeracility of the system as a wnole as ecuirec by General Design Criteria 37.
l.0 C:RE SFRAY REC RC'JLATION SYS~EM 2.1 Descriction.
The Core Soray Recirculati0n System is cesignec to orevent excessive water buildup in :ne containment sonere and to provide long term, ocs t-acc;:en: :coling.
The system consists :f two ACO ;pm pumos anc a heat excnanger.
~he cumos take suction f-em the icwer '.evels of :cn-tai nmen and cischarge to :ne core scray neacers. The system is actuatec manually anen :ne water level in the centainment rises to an elevaticn of 537 feet.
This elevation level will be achieved between 5 to 21 nours coeration of one core scray and cne containment spray channel.
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.o a.2 Ev al ua tien.
The 3ig Rock ?oint ?lant "ecnnical specificaticns s ecify that a test tank and apprcoriate valving is provided in tne Core Soray Recirculation System so the pump suction concitions ano ne ficw cnaracteristics of the sytem can be ceriodically tested.
The Core Spray Recirculation System is not tested f em -the manual actuation-thrcugh to the establishement of ficw during reactor operation as scecified by Stindard 3.eview Slan Section 7.2, Acpendix 3, Sec-ion 11.
Testing of tne Core Soray Recirculation System curing reactor operation is deamec 'moractical because f tne system's tecenaancy on tne Core Soray Sys tem.
However, the technical specifications :o not establish testing recuirements for 'he valves in 'he ficw path for the Core Spray Recir u-lation System nor is an integrated sys ems test equirec turing refueling to cetermine system cper ability.
5.0 S UMM AR Y he following h as been cetermined certaining to tne testing and test-ability of the Core Soray and Ccre Scray Recirculaticn Systems.
ine :esign Or otn t.s,e vore 2cray ano tne ucre acray,xecircul a-tien system make testing Of tne systems imaractical curing reac-cr oper ation.
2.
~he valves anc umes associa ed sitn *.he : re Scray System are periodically testec as is tne instrumentat co associatec nitn the i
s ys tem; h ow ev er, 'here is no systems integratec test recuired by the tecnnical specifications *o determir.e the Operability of the system as a uncie.
heref:re :ne systen ces kct :: moly :
Gener al Design C ir.eria 37.
3.
There are no esting ecuirements for tne valves 'in the ficw path of the Ccre Soray Recirculation System nor is there a requirement for a ceriodic systems integrated test to cetermine tne oper-ability Of the system as a uncle.
The system coes not ccmply to tne current eaccor licensing criteria.
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,e It is left to the NRC Staff to determine whetner enougn Operating exoerience at 3ig Rock Point can adeauately establish that tne present testing of the Core Spray and Core Spray Recirculatien Sys em assures a Idw procability ;f system f ailure.
6.0 R EFERENCES 1/
Apoendix "A" Consumers ?cwer Comoany Big Rock Point Plant Technical Scecifications Section 3.1. 4/ 4.1. 4 Emergency Core Cooling System, as amended througn February 25, 1981.
2.
General Cesign Cri:erien 37, " Testing of Emergency Ccre Ccoling Sys-tem," of Aapendi x A, " General Design Criteria for Nuclear Power 31 ants," 10 CFR Part 50, "Comestic Licensing of Procuction and Utili-ration Faci '. ities. "
3.
Br anch Tecnnical Position ICSB 25, " Guidance for the Interoretation of GDC 37 for Testing the Operacility of the Emergency Core Cooling Sys-tem as a Whole."
4 Regul atory Guide 1.22, " Periodic Testing of the Protection Sy. stem Actuation Functions."
5.
Nuclear Regulatory Commission Standard Review Pl an, Section 7.1, Accenaix 3, " Guidance for Ev aluation of Conformance to IEEE STD 279."
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