ML20247E780
| ML20247E780 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/05/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20247E778 | List: |
| References | |
| NUDOCS 8909150377 | |
| Download: ML20247E780 (5) | |
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UNITED STATES g
NUCLEAR REGULATORY COMMISSION 7n ij WASHINGTON, D. C. 20555
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION Pg.TEDTOAMENDMENTNO.'N TO PROVISIONAL OPERATING LICENSE N0. DPR-20 CONSUMERS POWER COMPANY I
PALISADES PLANT DOCKET NO. 50-255 i
i
1.0 INTRODUCTION
By letter dated September 15, 1988, Consumers Power Company proposed changes to the Pelisades Plant Appendix A Technical Specifications (TS) concerning the containment isolation system. This information was supplemented by the licensee by letter dated June 23, 1989. Consumers Power Company proposed to (1) manually operate the isolation valves associated with containment penetration 33 at power for the purpose of sampling the contents of the safety) irdection tanks, (2) add a containment isolation valve table (Table 3.6.1 in the TS, and (3) add an action statement for containment isolation valve inoperability and surveillance requirements for the valves. Censuners Power Company stated that the proposed change is in response to an issue identified in NRC Inspection Report 88-008 concerning a discrepancy in the as-built and operational configuration of the penetraticr. 33 valves.
In 1982, Consumers Power Compary identified a discrepancy between the FSAR description of containment penetration 33 and the existing method of satisfying a TS surveillance requirement. However, plans to either modify the penetration or submit a TS change request were drcpped without proper review. Based on this, NRC Region III issued inspection Report 88-008 on April 22, 1988 and transmitted a Notice of Violation to Consumers Power Company for failure to identify as an unreviewed safety question the current usage and classification of the penetration 33 isolation valve. Consumers Power Company performed a safety evaluation under 10 CFR 50.59 confirming the existance of an unreviewed safety question, and responded to the Notice of Violation by letters dated May 23, and September 2, 1988.
2.0 EVALUATION 2.1 TS Section 1.4, Miscellaneous Definitions - Containment integrity Containment integrity is defined to exist when all the following are true:
a.
All nonautomatic containment isolation valves and blind flanges are closed.
b.
The equipment door is properly closed and sealed.
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. c.
At least one door in each personnel air lock is properly closed and sealed.
d.
All automatic containment isolation valves are operable or are locked closed.
e.
Uncontrolled containment leakage satisfies Specification 4.5.1.
Consumers Power Company has proposed to revise the definition of containment integrity to allow opening of certain containment isolation valves at power. With the proposed change, containment integrity would be defined to exist when all the following are true:
a.
All non-automatic containment isolation valves and blind flanges are closed (operable) except as noted in Table 3.6.1.
1 b.
The equipment door is properly closed and sealed.
l c.
At least one door in each personnei air lock is properly closed and sealed.
d.
All automatic containment isolation valves are operable (as demonstrated by satisfying isolation times specified in Table 3.6.1 and leakage criterion in Specification 4.5.2) or are locked closed, e.
Uncontrolled containment leakage satisfies Specification 4.5.1.
The new Table 3.6.1, Containment Penetrations and Valves, specifies that the manual valves (MV-ES3234, MV-ES3234A) in penetration 33 are allowed to be opened for testing / sampling of the safety injection tanks no more than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per sample. Since these valves originally were not considered to be opened at power but are required to be opened periodically for sampling the contents of the safety injection tanks, i
Consumers Power Company proposes to change the TS to identify specifi-cally the valve actuation (opening) requirements.
Each of the four safety injection tanks has a 1" drain line penetrating the lower region of the tank. Each of these lines feeds into a common 2" header which passes through containment penetration 33. There are.two locked closed manual valves in series outside containment to maintain the penetration integrity.
Flow can be routed through these lines to the safety injection refueling water tank, equipment drain tank, or a sample tap located at the nuclear steam sampling l
system panel.
The current plant TS require monthly sampling of the safety injection tanks to ensure that the proper boron concentration is maintained in the tank water. However, the current TS do not allow the opening of manual containment isolation valves, specifically, unless the reactor is in the cold shutdown or refueling conditions.
Because the opening of the manual valves during power operation may reduce the margin of
y j
l of safety inherent to the Basis of TS 3.6 for ensuring containment integrity, Consumers Power Company performed a safety evaluation and provided the following justification:
1.
The system is not coupled to the primary coolant boundary, 2.
The valve operation is under administrative control which ensures that the valve is returned to its closed position after sampling, l
3.
The valves impact only the safety injection tank water level and the safety consequences of low level in the tank have been i
1 reviewed previously during issuance of a one-hour LCO in the TS, and 4.
A possible leakage path from the containment to the environment could exist only in the unlikely event that the safety injection tank drain line ruptures or two check valves between the reactor j
coolant pressure boundary and the safety injection tank discharge piping fail.
The staff has reviewed Consumers Power Company's submittals and finds that operating the safety injection tank sample line valves at power is acceptable because these valves do not constitute a containment i
atmospheric leakage path and the CE Standard Technical Specifications j
(STS) permit the opening of containment isolation valves at power on an. intermittent basis under administrative control.
2.2 TS Section 3.6.1 - Containment Integrity 1
TS Section 3.6.1.a. was revised to read:
" Containment integrity as defined in specification 1.4 shall not be violated unless the reactor is in the cold shutdown condition."
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This change would allow the opening of the two manually operated containment isolation valves in penetration 33 at times other than during cold shutdown or refueling. The staff finds the change accept-able as addressed in the above evaluation of TS Section 1.4.
Action statements were added to this TS section to read as follow:
"With one or more containment isolation valve (s) inoperable (including during performance of valve testing), maintain at least one isolation valve operable in each affected penetration that is open and either:
"a.
Restore the inoperable valve (s) to operable within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or "b.
Isolate each affected penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least one deactivated automatic valve secured in the isolation position or, i
a
l "c.
Isolate the affected penetration within 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least one closed manual valve or blind flange, or "d.
Be in at least hot shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />."
The current TS do not have action statements for inoperable containment i
isolation valves. The staff finds the added action statement for containment isolation valve inoperability to be appropriate to maintain containment integrity and to be in conformance with the guidelines of the CE STS.
Therefore, the proposed action statement is acceptable.
Consumers Power Company added the basis for the above action statement.
The staff concurs with Consumers Power Company's proposed basis.
New Table 3.6.1, Containment Penetrations and Valves, was added to list the automatic containment isolation valves and the manual valves in penetration 33.
The staff finds the added isolation valve table acceptable since it is consistent with the guidelines of the CE STS.
2.3 TS Section 3.6.5 - Containment Purge and Ventilation Systems Consumers Power Company revised this section by adding the following paragraph to the Basis:
"The current methed of maintaining Containment Building pressure below one psig is by the removal of non-condensible gases from the Containment Building through a clean waste reveiver tank whose rupture disc has been removed and then ultimately to the Plant stack. This path is isolated by two automatic isolation valves prior to entry into the Plant stack."
1 The added Basis addresses the method for maintaining the Containment Building at subatmospheric pressure with the vent path isolated. Since the vent path isolation is required to maintain containment integrity, the staff concurs in the revised Basis.
2.4 TS Section 4.5.6 Containment Isolation Yalves Consumers Power Company proposed to add TS Section 4.5.6 to read as follow:
"a.
The isolation valves shall be demonstrated operable by performance of a cycling test and verification of isolation time for auto isolation valves prior to returning the valve to service after maintenance, repair, or replacement work is performed on the valve or its associated actuator, control or power circuit.
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"b.
Each isolation valve shall be demonstrated operable by verifying that on each containment isolation right channel or left channel.
test signal, applicable isolation valves actuate to their required position during cold shutdown or at least once per refueling cycle.
"c.
The isolation time of each power operated or automatic valve shall be determined to be within its limit as specified in Table 3.6.1 when tested in accordance with Section XI of the ASME Boiler and Pressure Vessel Code."
The current TS.do not address surveillance requirements for containment isolation valves.
The staff finds that the new TS Section 4.5.6 provides appropriate surveillance requirements for the containment isolation valves and are consistent with the surveillance requirements specified in the guidelines of the CE STS and are, therefore, acceptable.
- 3. 0 ENVIRONMENTAL CONSIDERATION Pursuant to 10 CFR 51.21, 51.32, and 51.35, an environmental assessment and finding of no significant impact was published in the Federal Register on August 31, 1989.(54 FR 36068).
Accordingly, based upon the environmental assessment, the Commission has determined that issuance of this amendment-will not have a significant effect on the quality of the human environment.
4.0 CONCLUSION
l The staff has concluded, based on the considerations discussed above, that:
(1)lthere is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) 4 such activities will be conducted in compliance with the Commission's
(
regulations, and (3) the issuance of this amendment will not be inimical J
- to the common defense and security or to the health and safety of the i
L public.
l l
Principal Contributor:
J. S. Guo l
Dated: September 5, 1989 l
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