ML20198C992
| ML20198C992 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/15/1986 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20198C997 | List: |
| References | |
| IEB-85-003, IEB-85-3, NUDOCS 8605230105 | |
| Download: ML20198C992 (4) | |
Text
-
a
@ Consumers Kenneth W Berry c ar Exensmg mmunaws encaness General Offees-1945 West Parnali Road. Jackson, MI 49201. (517) 788-1636 May 15, 1986 James G Keppler, Administrator Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
RESPONSE TO IE BULLETIN 85-03 IE Bulletin 85-03 entitled " Motor-Operated Valve Common Mode Failures During Plant Transients Due to Improper Switch Settings, and dated November 15, 1985 requested the following:
For motor-operated valves in the high pressure coolant injection /
core spray and emergency feedwater systems (RCIC for BWRs) that are required to be tested for operational readiness in accordance with 10CFR50.55a(g), develop and implement a program to ensure that valve operator switches are selected, set and maintained properly. This should include the following conponents:
Review and document the design basis for the operation of each a.
valve. This documentation should include the maximum differential pressure expected during both opening and closing the valve for both normal and abnormal events to the extent that these valve operations and events are included it. the existing, approved design basis, (i.e., the design basis documented in pertinent licenseo submittals such as FSAR analyses and fully-approved operating and emergency procedures, etc). When determining the maximum differential pressure, those single equipment failures and inadvertent equipment operations (such as inadvertent valve closures or openings) that are within the plant design basis should be assumed.
In Response to item a, Consumers Power Company has generated the data contained in Attachment A to this submittal. The torque switch settings given in the table were obtained from the vendor in 1984 as part of our internal
) {
bo 55 MAY 1 9 M
(
52 OC0586-0089-NLO4 PDR O
m e
J G Keppler, Administrator 2
Palisades Plant Retronse to IE Bulletin 85-03 May 15, 1986 maintenance program. These settings are referenced in our maintenance procedures and are presently used as guidelines in setting the switches.
IE Bulletin 85-03 stated that once the data in item a was generated a program should be developed to accomplish the following:
b.
Using the results from item a above, establish the correct switch settings.
This shall include a program to review and revise, as necessary, the methods for selecting and setting all switches (i.e., torque, torque bypass, position limit, overload) for each valve operation (opening and closing).
If the licensee determines that a valve is inoperable, the licensee shall also make an appropriate justification for continued operation in accordance with the applicable technical specification.
c.
Individual valve settings shall be changed, as appropriate, to those established in item b, above. Whether the valve setting is. changed or not, the valve will be demonstrated to be operable by_ testing the valve at the maximum differential pressure determined in item a above with the exception that testing motor-operated valves under conditions simulating a break in the line containing the valve is not required.
Otherwise, justification should be provided for any cases where testing with the maximum differential pressure cannot practicably be performed. This justification should include the alternative to maximum differential pressure testing which will be used to verify the correct settings.
Note: This bulletin is not intended to establish a requirement for valve testing for the condition simulating a break in the line containing the valve. However, to the extent that such valve operation is relied upon in the design basis, a break in the line containing the valve should be considered in the analyses prescribed in items a and b above. The resulting switch settings for pipe break conditions should be verified, to the extent practical, by the same methods that would be used to verify other settings (if any) that are not tested at the maximum differential pressure.
.d.
Prepare or revise procedures to ensure that correct switch settings are determined and maintained throughout the life of the plant. Ensure that applicable industry recommendations are considered in the preparation of these procedures.
Consumers Power Company has developed the following program with a projected completion date being the end of the 1987 refueling outage.
OC0586-0089-NLO4
--.=.
J'G'Keppler, Administrator 3
Palisades Plant Response to IE Bulletin 85-03 May 15, 1986 IE Bulletin 85-03 Completion Program 1.
The existing switch settings shall be verified as being correct for each valve operation (opening and closing), when the maximum differential pressure listed in Attachment A is taken into account. This verification will be done by physical testing during the 1987 refueling outage.
2.
Changes will be made to individual valve settings, as necessary, to incorporate findings in 1. above. Valves listed in Attachment A will be demonstrated operable by testing the valves at the maximum differential pressure, if practical. It should be noted that if a valve listed in Attachment A cannot be tested at maximum differential pressure, justification will be provided including the alternative to maximum differential pressure testing, which will be used to verify the correct settings.
3.
Control and maintenance of switch settings will be explicitly added to the existing plant modification program. Maintenance Procedures will be reviewed to insure the existing instructions are adequate to insure proper setting and maintenance of the switch settings, given the new information obtained in the above efforts.
Upon completion of the above program a written report will be submitted to the NRC.
Kenneth W Berry (Signed)
Kenneth W Berry Director, Nuclear Licensing CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector - Palisades Attachment OC0586-0089-NLO4
CONSUMERS POWER COMPANY Palisades Plant Docket 50-255 - License DPR-20 RESPONSE TO IE BULLETIN 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 Commission's Rule and Regulations thereunder, Consumers Power Company submits our response to IE Bulletin 85-03 dated November 15, 1985 entitled " Motor Operated Valve Common Mode Failures During Plant Transients Due to Improper Switch Settings."
Consumers Power Company's response is dated May 15, 1986.
CONSUMERS POWER COMPANY By F W Buckman (Signed)
F W Buckman, Vice President Nuclear Operations Sworn and subscribed to before me this 15th day of May, 1986.
Elaine E Buehrer (Signed)
[ SEAL]
Elaine E Buehrer, Notary Public Jackson County My commission expires October 31, 1989 OC0586-0089-NLO4
.