ML20050C784

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Forwards Revised Response to NUREG-0737 Item II.D.1 Re Relief Valve Testing Requirements.Response Will Be Included in Next FSAR Revision
ML20050C784
Person / Time
Site: Midland
Issue date: 04/08/1982
From: Jackie Cook
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To: Harold Denton
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.D.1, TASK-TM 16598, NUDOCS 8204090353
Download: ML20050C784 (4)


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3 Consumers power Company Vice President - Projects, Engineering anJ Construction Genevel offices: 1945 West Pernell Road, Jackson, MI 49201 * (517) 78& O453 m

April 8, 1982 s

liarold R Denton, Director y/

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Office of Nuclear Reactor Regulation p.

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I US Nuclear Regulatory Commission 7,kgk i

Washington, DC 20555 s

MIDLAND PROJECT MIDLAND DOCKET NOS 50-329, 50-330 g

g REVISED RESPONSE TO ITEM II.D.1 0F NUREG-0737 FILE:

0505.805 SERIAL:

16598 ENCLOSURE (1): Revised Response to Item II.D.1 of NUREG-0737 As discussed with liarold Gregg of MEB, CP Co is revising the response to NUREG-0737, Item II.D.I.

The revised response will be included in the next FSAR revision and conunits CP Co to provide the NRC with Midland plant specific submittals for safety and power operated relief valve (PORV) qualification, PORV block valve qualification and SV/PORV discharge piping support evaluation by Unit 2 fuel load as required by Enclosure 2 of NUREG-0737.

In addition, the block valves will be operationally tested during hot functional testing.

Enclosed is a copy of the revised response for Item II.D.1 of NUREG-0737.

We believe the response provided in this letter will assist the Staff in writing the SER for Item II.D.1 of NUREG-0737.

JWC/ PEP /ims CC RJCook, Midland Resident Inspector pO/

Rllernan, US NRC 3

FCherny, US NRC DBMiller, Midland Construction (3)

/ /

RWifuston, Washington oc0382-0831a131 l

8204090353 820408 PDR ADOCK 05000329 i

A PDR

MIDLAND 162-FSAR 3

RESPONSES TO POST-TMI-2 ISSUES AND EVENTS PART I NUREG-0737 RESPONSES Item II.D.1 - Relief Valve Testing Requirements

.R." HP 0 n,_s_e As a sponsor of the EPRI PWR Safety and Relief Valve Test Program, Consumers Power Company intends to comply with the recommendations of NUREG-0578, Item 2.1.2 as implemented by NUREG-0660 Item II.D.1 and clarified by NUREG-0737, Item II.D.I.

A letter by R.C. Youngdahl f Consumers Power Company, December 15, 1980, provides the current PWR utilities' positions on NUREG-0737, Item II.D.1 clarifications.

Those positions are contained in the following synopses.

a.

Safety and Relief Valves and Piping: The EPRI program Plan for Performance Testing of PWR Safety and Relief Valves, Revision 1, July 1,1980, provides a generic program and data f rom which CP Co can satisfy the NRC requirements.

b.

Block Valves:

The EPRI program has not formally included the testing of block valves.

Ilowever, a small number of block valves have been tested at the Marshall Steam Station Test facility. The PWR utilities and EPRI cannot provide a detailed block valve test program until results of the Wyle and CE relief valve tests are l

available.

The PWR utilities and EPRI believe that the proper operation of the TMI-2 and Crystal River block valves and other operational experience, plus knocledge of the Marshall tests, support a less hurried and more rational approach to block valve testing.

Each Midland Unit has two block valves (one manufactured by Anchor Darling and one by Target Rock) in series upstream of the PORV.

CP Co intends to perform opera-tional steam testing of each valve during hot functional testing to provide evidence that the block valves can be operated, at normal operational pressure and temper-ature, ie, closed and opened at full D/P and at full flow.

c.

Anticipated Transient Nithout Scram (ATWS) Testing - PWR utilities will not support additional efforts for ATVS testint; until regulatory issues are resolved.

The major safety and relief valve test facility (CE) is complete l

and some measures were taken to provide additional test capability beyond the current program requirements. The NRC should recognize the results from the current program are likely to provide most of the information necessary to address ATWS events (ie, relief capability at high pressures).

I-25 Revision

MIDLAND 162-FSAR RESPONSES TO POST-TMI-2 ISSUES AND EVENTS PARf I NUREG-0737 RESPONSES The Midland power-operated relief valve (PORV) is manufactured by Target Rock, is safety grade and is basically the same valve as the one tested by EPRI at the Marshall and Wyle facilities. A preliminary review of the Target Rock PORV test results -9ntained in the EPRI PWR Safety and Relief Valve Test Program Interim Data Report (July 1981), Indicates that this valve performed satisfac-torily for all tests with one exception.

This exception, Test 7-TR-7W performed at the Wyle facility, had a loop seal configuration upstream of the PORV.

The piping layout at Midland includes a continuous downward slope of the piping from the PORV to the pressurizer and does not include a loop seal.

Based on the preliminary review of the generic program results and subject to the issue of the B&W Test Condition Justification Report, CP Co believes that the EPRI program confirms the adequacy of the PORV.

The Midland pressurizer safety valves are 2!$ x 6 inch Dresser 31739A models with a short inlet configuration.

The EPRI test results for this valve are still being reviewed and evaluated.

CP Co will provide, before fuel load, the Midland plant specific submittals for safety and relief valve qualification, piping and support evaluation and block valve qualification, as required by to NUREG-0737.

j I-26 Revision

6 1

1 CONSUMERS POWER COMPANY Midland Units 1 and 2 Docket No 50-329, 50-330 Letter Serial 16598 Dated April 8, 1982 At the request of the Commission and pursuant to the Atomic Energy Act of 1954, and the Energy Reorganization Act of 1974, as amended and the l

Commission's Rules and Regulations thereunder, Consumere Power Company submits a revised FSAR response to NUREG-0737, Item II.D.1, Relief Valve Testing Requireiments.

I CONSUMERS POWER COMPANY By J W Cook, Vice President Pro

  • cts, Engineering and Construction Sworn and subscribed before me this 8

day of 19f2.

^-~'=-2 Notary Public Jackson County, Michigan d

My Commission Expires, 7

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