|
|
Line 3: |
Line 3: |
| | issue date = 07/01/1997 | | | issue date = 07/01/1997 |
| | title = Forwards Description of Change in Commitments Made in 180-day Response to GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves. | | | title = Forwards Description of Change in Commitments Made in 180-day Response to GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves. |
| | author name = BORDINE T C | | | author name = Bordine T |
| | author affiliation = CMS ENERGY CORP. | | | author affiliation = CMS ENERGY CORP. |
| | addressee name = | | | addressee name = |
|
---|
Category:CORRESPONDENCE-LETTERS
MONTHYEARML18066A6871999-10-19019 October 1999 Forwards Response to NRC 990908 RAI Re Inservice Insp Program Relief Request 14.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6881999-10-19019 October 1999 Forwards Rev 5 to Palisades Nuclear Plant COLR, Per Requirements of TS 6.6.5.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6741999-10-0202 October 1999 Forwards MOR for Sept 1999 for Palisades Nuclear Plant & Operating Data Rept Sheet for Month of Aug 1999.MOR for Aug 1999 Inadvertently Had Copy of Ref Data Sheet for Apr 1999 Data ML18066A6791999-10-0101 October 1999 Provides Response to RAI Re Draft Rept, Study of Air- Operated Valves in Us Nuclear Power Plants. ML18066A6621999-09-30030 September 1999 Notifies NRC That Util Will Implement ITS at Plant on or Before Oct 31,2000 & Attachments 1 & 2 Contains Request for License Condition Which Relates First Performance of New or Revised Surveillance Requirements to Implementation of ITS ML18066A6601999-09-29029 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations. ML18066A6471999-09-17017 September 1999 Forwards Final Clean Copies of ITS & Bases Pages Which Incorporate All Changes Proposed in Listed Ltrs.Clean Copies Also Incorporate Some Editorial Changes & Bases Clarifications as Result of Ongoing Reviews to LCOs ML18066A6331999-09-0202 September 1999 Forwards Monthly Operating Rept for Aug 1999 & Revised Monthly Operating Rept for Apr 1999 for Palisades Nuclear Plant ML18066A6261999-08-26026 August 1999 Forwards Addl New Valve Relief Request as Alternative to Code Requirements That Will Provide Acceptable Level of Quality & Safety.Request Would Allow Use of App II, Check Valve Condition Monitoring Program, of ASME OM Code-1995 ML20211D5661999-08-17017 August 1999 Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d).Attachments 1 & 2 Summarize Test Results at Palisades Plant,Big Rock Point Plant & Corporate Ofc ML18066A6111999-08-13013 August 1999 Requests Exemption from Certain Requirements of 10CFR50,App R, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101. Request Concerns Oil Collection Sys Requirements for PCP Motors ML18066A5881999-07-30030 July 1999 Provides Rev to Instrument Channel Drift Measurement Submitted on 990611,in Response to NRC Comments on Util RAI Response for Sections 3.3,3.5 & 3.6 & Editorial Changes Revs Necessary for Consistency within ITS ML18066A5921999-07-30030 July 1999 Forwards Results of Review by Consumers Energy of Two NRC Draft Repts Entitled, Evaluation of Air-Operated Valves at Light-Water Reactors & Study of Air-Operated Valves in Us Nuclear Power Plants. ML18066A5971999-07-30030 July 1999 Forwards Markup of Draft NRC SE Re Util Proposal to Convert to Its.Ltr Contains No New Commitments & No Revs to Existing Commitments ML20210G8351999-07-29029 July 1999 Final Response to FOIA Request for Documents.Records in App a Encl & Will Be Available in PDR ML18066A5651999-07-19019 July 1999 Forwards Corrections to Previously Submitted TS Section 3.7, Plant Systems, Converting to Its,Per NUREG-1432.Licensee Realized That Certain Provisions of CTS Had Been Inappropriately Replaced with Provisions from STS ML18066A5111999-06-29029 June 1999 Provides Voluntary Confirmation of Facility Readiness as Outlined in GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Disclosure & Response Encl ML20209B2081999-06-29029 June 1999 Discusses Closure of Response to RAI Re GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity. Rvid,Version 2 Issued as Result of Review of Responses.Info Should Be Reviewed & Comments Submitted by 990901 ML20210G8791999-06-23023 June 1999 FOIA Request for All Document Communications Between NRC & Region III Involving R Landsman,B Jorgensen & R Caniano & NRC Staff Under Their Supervision & All Communications in Their Possession to & from Consumers Power Re Plant ML18066A5061999-06-17017 June 1999 Forwards Responses to NRC Questions for ITS LCOs 3.6.3 & 3.6.6 of 990126 Submittal.One Editorial Change in Addition to Those Made in Response to NRC Comments & Conforming Changes Made to Associated Bases,Encl ML18066A4991999-06-11011 June 1999 Forwards Responses to NRC Comments Re ITS Section 3.3 & Associated Revs to ITS Sections 1.0,3.3,3.4 & 3.9 of 990126 ITS Conversion Submittal.One Technical Change & Several Editorial Changes Unrelated to NRC Comments,Also Provided IR 05000255/19970181999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18066A4921999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18068A6011999-06-0808 June 1999 Forwards Description of Recent Changes Made to Palisades Site Emergency Plan,Excluding Minor & Editorial Changes Not Requiring Further Explanation ML18066A4881999-06-0404 June 1999 Provides Responses to NRC Questions & Associated Editorial Revs for ITS LCOs 3.6.1,3.6.2,3.6.4,3.6.5 & 3.6.7 of 980126 Submittal.Responses to Comments on Remaining Section 3.6 LCOs Will Be Submitted Separately ML18066A4801999-05-24024 May 1999 Forwards Copy of Rev to NPDES Permit Number MI0001457 Renewal Application as Submitted to Mi Dept of Environ Quality on 990513 ML18066A4721999-05-18018 May 1999 Informs That During Period from 981101-990430,there Were No NPDES Permit Violations & No Repts of Oil,Salt or Polluting Matl Losses Were Made to Govt Agencies ML18066A4651999-05-17017 May 1999 Forwards ISI Program Relief Request 14 for NRC Approval in Accordance with 10CFR50.55(a)(3) as Requirement for Which Proposed Alternative Provide Acceptable Level of Quality & Safety.Rev 0 to SIR-99-032 Rept Also Encl ML18066A4611999-05-14014 May 1999 Requests Approval to Use Alternative Requirements IAW 10CFR50.55a(a)(3)(i),proposing to Follow Requirements of ASME Boiler & Pressure Vessel Code Case N-566-1.IST Program Relief Request 6 for NRC Approval Encl ML18068A5831999-05-0303 May 1999 Forwards Proposed TS Section 3.5,in Response to NRC 990317 RAI Re Util 980126 TS Change Request Re Conversion to Improved Ts,Per NUREG-1432 ML20206J2411999-04-30030 April 1999 Submits Corrected Copy of Ltr Forwarding 1998 Consumers Energy Co Annual Rept. Ltr Contains Corrected Docket & License Number for Big Rock Point.With One Oversize Encl ML20217A8191999-04-29029 April 1999 Forwards Listed Matls Related to Palisades Plant June 1999 Initial License Exam ML20206E8271999-04-28028 April 1999 Forwards Palisades Plant Annual Radiological Environ Operating Rept for 1998. There Were No Reportable Events During This Period ML20207B4661999-04-23023 April 1999 Forwards Copy of Final Exercise Rept for Biennial Radiological Emergency Preparedness Exercise Conducted on 981201 for Palisades Npp.No Deficiencies Noted.Seven New Arcas Identified ML18066A4531999-04-0707 April 1999 Forwards ITS Pages 3.1.4-2 & 3.1.4-8,revising Completion Time for Action D.1,as Requested by NRC 990406 Telcon,Per TS Change Request Submitted 980126.Change Submitted Does Not Alter Conclusions of No Signficant Hazards Considerations ML18066A4481999-04-0202 April 1999 Responds to Violations Noted in Insp Rept 50-255/98-06. Corrective Actions:Nuclear Performance Assessment Dept Has Reviewed Observations & Agrees That Field Observations by Qualified Personnel Are Important Aspect of Program ML18066A4471999-03-30030 March 1999 Confirms Completion of Util Review of Design Engineering Contractor Cable Ampacity Evaluation.Evaluation Available at Plant for NRC Review ML18066A4411999-03-30030 March 1999 Forwards Response to NRC 990126 RAI Re TS Section 3.7 of Util 980126 LAR Request for Conversion to Its.Licensee Received Permission to Delay TS Section 3.6 Response to Allow for Addl Time for Preparation & Internal Review ML18066A4441999-03-26026 March 1999 Submits Certification of Financial Assurance for Decommissioning of Palisades Nuclear Plant.Certified Rept of Status of Consumers Energy Co Decommissioning Funding & Trust Agreement Encl as Attachments 1 & 2 ML18066A4401999-03-25025 March 1999 Forwards Revised Best Estimate Fluence Evaluation Using Industry Data, Providing Justification for Using Industry Data to Determine Best Estimate Fluence.Review of Info & SE Requested ML18066A4191999-03-23023 March 1999 Forwards 1998 Annual Radioactive Effluent Release & Disposal Rept, for Palisades Plant,Providing Summary of Quantities of Radioactive Liquid & Gaseous Effluent Releases & Solid Radioactive Waste Processed During 1998 ML18066A4231999-03-22022 March 1999 Forwards Answers to 990311 Telcon Request for Addl Clarification & Revs Re ITS Section 3.4.Markups of Previously Submitted TS Pages & Revised Pages for Section 3.4 Also Encl ML20204F2091999-03-18018 March 1999 Requests That Listed TS Change Requests (Tscrs) Be Issued with Allowance That Tscrs Be Fully Implemented within Sixty Days of Issuance.Request Will Allow Time for Completion of Final Training & Procedure Changes Associated with Amend ML18066A4121999-03-18018 March 1999 Concludes That Mod to Provide Automatic Switchover of Control Room Heating,Ventilation & Air Conditioning (CRHVAC) Sys to Emergency Mode Is Not Needed to Meet Regulatory Requirements.Mod Commitment Cancelled ML18066A4141999-03-18018 March 1999 Forwards Rev 4 to COLR, Containing Limits for Fuel Cycle 14 & Future Cycles ML20204E5861999-03-16016 March 1999 Submits Current Limits of Property Insurance Maintained at Consumers Energy Co Operating Nuclear Power Plants ML18066A4131999-03-11011 March 1999 Responds to NRC 990210 Ltr Re Violations Noted in Insp Rept 50-255/98-22.Corrective Actions:Analytical Evaluation, EA-C-PAL-98-1067-01, P-50A Case to Cover Stud Evaluation, Was Submitted to NRC on 981220 ML18068A5241999-02-12012 February 1999 Resubmits Relief Request 12,with Addl Info That Includes Specific Locations Where Relief Request Would Be Applied,Per 10CFR50.55a(g)(5)(iii) ML18068A5211999-02-11011 February 1999 Informs NRC That Implementation of Formal Industry Position on Severe Accident Mgt at Palisades Plant Was Completed on 981217 ML20203F2541999-02-10010 February 1999 Informs That Beginning 990216,DE Hills Will Be Chief of Operations Branch Which Includes Operator Licensing Function 1999-09-30
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML18066A6871999-10-19019 October 1999 Forwards Response to NRC 990908 RAI Re Inservice Insp Program Relief Request 14.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6881999-10-19019 October 1999 Forwards Rev 5 to Palisades Nuclear Plant COLR, Per Requirements of TS 6.6.5.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6741999-10-0202 October 1999 Forwards MOR for Sept 1999 for Palisades Nuclear Plant & Operating Data Rept Sheet for Month of Aug 1999.MOR for Aug 1999 Inadvertently Had Copy of Ref Data Sheet for Apr 1999 Data ML18066A6791999-10-0101 October 1999 Provides Response to RAI Re Draft Rept, Study of Air- Operated Valves in Us Nuclear Power Plants. ML18066A6621999-09-30030 September 1999 Notifies NRC That Util Will Implement ITS at Plant on or Before Oct 31,2000 & Attachments 1 & 2 Contains Request for License Condition Which Relates First Performance of New or Revised Surveillance Requirements to Implementation of ITS ML18066A6601999-09-29029 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations. ML18066A6471999-09-17017 September 1999 Forwards Final Clean Copies of ITS & Bases Pages Which Incorporate All Changes Proposed in Listed Ltrs.Clean Copies Also Incorporate Some Editorial Changes & Bases Clarifications as Result of Ongoing Reviews to LCOs ML18066A6331999-09-0202 September 1999 Forwards Monthly Operating Rept for Aug 1999 & Revised Monthly Operating Rept for Apr 1999 for Palisades Nuclear Plant ML18066A6261999-08-26026 August 1999 Forwards Addl New Valve Relief Request as Alternative to Code Requirements That Will Provide Acceptable Level of Quality & Safety.Request Would Allow Use of App II, Check Valve Condition Monitoring Program, of ASME OM Code-1995 ML20211D5661999-08-17017 August 1999 Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d).Attachments 1 & 2 Summarize Test Results at Palisades Plant,Big Rock Point Plant & Corporate Ofc ML18066A6111999-08-13013 August 1999 Requests Exemption from Certain Requirements of 10CFR50,App R, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101. Request Concerns Oil Collection Sys Requirements for PCP Motors ML18066A5971999-07-30030 July 1999 Forwards Markup of Draft NRC SE Re Util Proposal to Convert to Its.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A5881999-07-30030 July 1999 Provides Rev to Instrument Channel Drift Measurement Submitted on 990611,in Response to NRC Comments on Util RAI Response for Sections 3.3,3.5 & 3.6 & Editorial Changes Revs Necessary for Consistency within ITS ML18066A5921999-07-30030 July 1999 Forwards Results of Review by Consumers Energy of Two NRC Draft Repts Entitled, Evaluation of Air-Operated Valves at Light-Water Reactors & Study of Air-Operated Valves in Us Nuclear Power Plants. ML18066A5651999-07-19019 July 1999 Forwards Corrections to Previously Submitted TS Section 3.7, Plant Systems, Converting to Its,Per NUREG-1432.Licensee Realized That Certain Provisions of CTS Had Been Inappropriately Replaced with Provisions from STS ML18066A5111999-06-29029 June 1999 Provides Voluntary Confirmation of Facility Readiness as Outlined in GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Disclosure & Response Encl ML20210G8791999-06-23023 June 1999 FOIA Request for All Document Communications Between NRC & Region III Involving R Landsman,B Jorgensen & R Caniano & NRC Staff Under Their Supervision & All Communications in Their Possession to & from Consumers Power Re Plant ML18066A5061999-06-17017 June 1999 Forwards Responses to NRC Questions for ITS LCOs 3.6.3 & 3.6.6 of 990126 Submittal.One Editorial Change in Addition to Those Made in Response to NRC Comments & Conforming Changes Made to Associated Bases,Encl ML18066A4991999-06-11011 June 1999 Forwards Responses to NRC Comments Re ITS Section 3.3 & Associated Revs to ITS Sections 1.0,3.3,3.4 & 3.9 of 990126 ITS Conversion Submittal.One Technical Change & Several Editorial Changes Unrelated to NRC Comments,Also Provided IR 05000255/19970181999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18066A4921999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18068A6011999-06-0808 June 1999 Forwards Description of Recent Changes Made to Palisades Site Emergency Plan,Excluding Minor & Editorial Changes Not Requiring Further Explanation ML18066A4881999-06-0404 June 1999 Provides Responses to NRC Questions & Associated Editorial Revs for ITS LCOs 3.6.1,3.6.2,3.6.4,3.6.5 & 3.6.7 of 980126 Submittal.Responses to Comments on Remaining Section 3.6 LCOs Will Be Submitted Separately ML18066A4801999-05-24024 May 1999 Forwards Copy of Rev to NPDES Permit Number MI0001457 Renewal Application as Submitted to Mi Dept of Environ Quality on 990513 ML18066A4721999-05-18018 May 1999 Informs That During Period from 981101-990430,there Were No NPDES Permit Violations & No Repts of Oil,Salt or Polluting Matl Losses Were Made to Govt Agencies ML18066A4651999-05-17017 May 1999 Forwards ISI Program Relief Request 14 for NRC Approval in Accordance with 10CFR50.55(a)(3) as Requirement for Which Proposed Alternative Provide Acceptable Level of Quality & Safety.Rev 0 to SIR-99-032 Rept Also Encl ML18066A4611999-05-14014 May 1999 Requests Approval to Use Alternative Requirements IAW 10CFR50.55a(a)(3)(i),proposing to Follow Requirements of ASME Boiler & Pressure Vessel Code Case N-566-1.IST Program Relief Request 6 for NRC Approval Encl ML18068A5831999-05-0303 May 1999 Forwards Proposed TS Section 3.5,in Response to NRC 990317 RAI Re Util 980126 TS Change Request Re Conversion to Improved Ts,Per NUREG-1432 ML20206J2411999-04-30030 April 1999 Submits Corrected Copy of Ltr Forwarding 1998 Consumers Energy Co Annual Rept. Ltr Contains Corrected Docket & License Number for Big Rock Point.With One Oversize Encl ML20217A8191999-04-29029 April 1999 Forwards Listed Matls Related to Palisades Plant June 1999 Initial License Exam ML20206E8271999-04-28028 April 1999 Forwards Palisades Plant Annual Radiological Environ Operating Rept for 1998. There Were No Reportable Events During This Period ML20207B4661999-04-23023 April 1999 Forwards Copy of Final Exercise Rept for Biennial Radiological Emergency Preparedness Exercise Conducted on 981201 for Palisades Npp.No Deficiencies Noted.Seven New Arcas Identified ML18066A4531999-04-0707 April 1999 Forwards ITS Pages 3.1.4-2 & 3.1.4-8,revising Completion Time for Action D.1,as Requested by NRC 990406 Telcon,Per TS Change Request Submitted 980126.Change Submitted Does Not Alter Conclusions of No Signficant Hazards Considerations ML18066A4481999-04-0202 April 1999 Responds to Violations Noted in Insp Rept 50-255/98-06. Corrective Actions:Nuclear Performance Assessment Dept Has Reviewed Observations & Agrees That Field Observations by Qualified Personnel Are Important Aspect of Program ML18066A4471999-03-30030 March 1999 Confirms Completion of Util Review of Design Engineering Contractor Cable Ampacity Evaluation.Evaluation Available at Plant for NRC Review ML18066A4411999-03-30030 March 1999 Forwards Response to NRC 990126 RAI Re TS Section 3.7 of Util 980126 LAR Request for Conversion to Its.Licensee Received Permission to Delay TS Section 3.6 Response to Allow for Addl Time for Preparation & Internal Review ML18066A4441999-03-26026 March 1999 Submits Certification of Financial Assurance for Decommissioning of Palisades Nuclear Plant.Certified Rept of Status of Consumers Energy Co Decommissioning Funding & Trust Agreement Encl as Attachments 1 & 2 ML18066A4401999-03-25025 March 1999 Forwards Revised Best Estimate Fluence Evaluation Using Industry Data, Providing Justification for Using Industry Data to Determine Best Estimate Fluence.Review of Info & SE Requested ML18066A4191999-03-23023 March 1999 Forwards 1998 Annual Radioactive Effluent Release & Disposal Rept, for Palisades Plant,Providing Summary of Quantities of Radioactive Liquid & Gaseous Effluent Releases & Solid Radioactive Waste Processed During 1998 ML18066A4231999-03-22022 March 1999 Forwards Answers to 990311 Telcon Request for Addl Clarification & Revs Re ITS Section 3.4.Markups of Previously Submitted TS Pages & Revised Pages for Section 3.4 Also Encl ML20204F2091999-03-18018 March 1999 Requests That Listed TS Change Requests (Tscrs) Be Issued with Allowance That Tscrs Be Fully Implemented within Sixty Days of Issuance.Request Will Allow Time for Completion of Final Training & Procedure Changes Associated with Amend ML18066A4141999-03-18018 March 1999 Forwards Rev 4 to COLR, Containing Limits for Fuel Cycle 14 & Future Cycles ML18066A4121999-03-18018 March 1999 Concludes That Mod to Provide Automatic Switchover of Control Room Heating,Ventilation & Air Conditioning (CRHVAC) Sys to Emergency Mode Is Not Needed to Meet Regulatory Requirements.Mod Commitment Cancelled ML20204E5861999-03-16016 March 1999 Submits Current Limits of Property Insurance Maintained at Consumers Energy Co Operating Nuclear Power Plants ML18066A4131999-03-11011 March 1999 Responds to NRC 990210 Ltr Re Violations Noted in Insp Rept 50-255/98-22.Corrective Actions:Analytical Evaluation, EA-C-PAL-98-1067-01, P-50A Case to Cover Stud Evaluation, Was Submitted to NRC on 981220 ML18068A5241999-02-12012 February 1999 Resubmits Relief Request 12,with Addl Info That Includes Specific Locations Where Relief Request Would Be Applied,Per 10CFR50.55a(g)(5)(iii) ML18068A5211999-02-11011 February 1999 Informs NRC That Implementation of Formal Industry Position on Severe Accident Mgt at Palisades Plant Was Completed on 981217 ML18066A4051999-02-10010 February 1999 Requests Copy of Consumers Energy (Palisades) Formal Response to RAI Dtd 990512 (USI A-46) ML18066A3921999-01-29029 January 1999 Forwards Licensee Interpretation of TS Requirements for Performance of SRs as Applied to Instrumentation Channel Calibr.Ltr Established No New Commitments ML18066A3891999-01-28028 January 1999 Submits Response to Concern Expressed in Insp Rept 50-255/98-06 Re Whether Palisades ISI Program Was Being Conducted IAW Applicable Requirements 1999-09-30
[Table view] |
Text
{{#Wiki_filter:. .L*\ ( I A CMS Energy Company July 1, 1997 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 DOCKET 50-255 -LICENSE DPR-20 -PALISADES PLANT
- Thoma* t:. Bordlml Manager Licensing CHANGE IN COMMITMENTS MADE IN 180-DAY RESPONSE TO GENERIC LETTER 95-07 On February 13, 1996, the Palisades Plant submitted the 180-day response to Generic Letter 95-07, "Pressure Locking and Thermal Binding of Safety-Related Operated Gate Valves". Within that letter, three commitments were made to alleviate potential pressure locking or thermal binding situations involving the power operated relief valve (PORV) Block Valves (M0-1042A and M0-1043A) and the high pressure safety injection (HPSI) Pump Subcooling Isolation Valves (CV-3070 and CV-3071 ). These commitments were: 1. The susceptibility of the PORV Block Valves to possible pressure locking will be eliminated by modification of the valve disc or by a system operating configuration change. 2. The operating procedures will be revised to reduce the temperature differential seen by the PORV Block Valves. 3. The HPSI Pump Subcooling Isolation Valves will be modified by drilling a hole in Ii the valve discs to equalize the bonnet and high side line pressure.
l Ps-e61-e-{ 9707080053 970701 PDR ADOCK 05000255 P PDR I llllll lllll lllll lllll lllll llllll Ill llll
- I 111 4 1 7 0
- Q 7 0 !) r:-:; rfalisades Nuclear Plant
- 27780 Blue Star Memorial Highway
- Covtiil, Ml 49043
- Tel: 616 764 2913
- Fax: 616 764 2490 t, v* (j
- * ... Commitment 1 has been completed.
This was accomplished during the 1996 refueling outage by drilling a hole in each PORV Block Valve upstream disc to equalize the bonnet and the upstream line pressures.
Further evaluation has resulted in a need to revise the methods to be used to accomplish the actions of Commitments 2 and 3. These evaluations are contained in Attachments 1 and 2, respectively.
SUMMARY
OF COMMITMENTS This letter contains no new commitments and revisions to two existing commitments.
The revised commitments are: 2 2. The control switch trip of the PORV Block Valve motor operators will be changed from torque switch closed to limit switch closed in order to reduce the susceptibility for thermal binding. 3. The bonnets of the HPSI Pump Subcooling Isolation Valves will be connected, through existing bonnet leak off lines, to the upstream piping to equalize the bonnet and high side line pressure in order to eliminate the susceptibility for .pressure locking.
- The completion date of the revised commitments remains as the end of the 1998 refueling outage. Thomas C. Berdine Manager, Licensing CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector
-Palisades Attachments 1 and 2
- CONSUMERS ENERGY COMPANY To the best of my knowledge, the contents of this letter revising commitments made in the 180-day response to Generic Letter 95-07, are truthful and complete.
ThOfTlaSC, Manager, Licensing Sworn and subscribed to before me this ;d day of 1997.
Alora M. Davis, Notary Public Berrien County, Michigan (Acting in Van County, Michigan)
My commission expires August 26, 1999
- ATTACHMENT 1 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 CHANGE IN COMMITMENTS MADE IN 180-DA Y RESPONSE TO GENERIC LETTER 95-07 COMMITMENT 2: THERMAL BINDING POTENTIAL IN PORV BLOCK VALVES 3 Pages
- * *COMMITMENT 2: THERMAL BINDING POTENTIAL IN PORV BLOCK VALVES The purpose of this evaluation is to provide justification to revise the current commitment for the reduction of PORV Block Valve thermal binding susceptibility by replacing the proposed operating procedure changes with a modification to the motor operators.
Thermal binding occurs in double disk gate valves which are closed hot and allowed to cool. Contractions occurring during cooldown can cause a valve to become thermally bound and may prevent opening at the cooler temperature.
Temperature differences greater than 100°F are considered a threshold for thermal binding susceptibility.
The PORV Block Valves are 4 inch, double disk Edwards gate valves with Limitorque motor operators.
They are normally closed during power operation and are closed/opened during heatup/cooldown to disable/enable low temperature overpressure protection (L TOP). The PORV Block Valves are found to be susceptible to thermal binding because they are double disk gate valves and may become thermally bound during certain plant conditions.
For the Palisades PORV Block Valves, operating procedures permit closure at . temperatures as high as 643°F with subsequent opening as low as 495°F, a maximum *temperature difference of 148°F. Valve closure occurs during plant heatup when L TOP is disabled.
Operating Procedure SOP-1, "Primary Coolant System", specifies disarming L TOP and closure of the PORV Block Valves when PCS temperature is greater than 460°F. Using the Saturation Curve of the Pressure and Temperature Limit Curves in SOP-1, Attachment 2, the corresponding Pressurizer temperature can be as high as 643°F (temperature at the highest PCS pressure, 2100 psia, for saturated conditions).
This high temperature, while procedurally permissible, represents an extreme departure from the normal way the plant is operated.
The PORV Blocks are typically closed soon after heatup past the 460°F permissive temperature.
The high temperature is also conservative since it assumes valve temperature follows Pressurizer temperatures at saturated steam conditions.
It does not account for heat loss in the piping to the block valves or any lag time required for valve heat up. PORV Block Valve opening occurs during plant cooldown to enable L TOP and can occur at a temperature as low as 495°F. SOP:-1, Attachment 2 requires L TOP to be enabled whenever PCS temperature is less than 430°F. Using the Pressure and Temperature Limit Curves in SOP-1, Attachment 2, this can occur at a minimum PCS pressure of 650 psia which corresponds to a Pressurizer temperature of 495°F (temperature at saturated steam conditions).
As stated in the February 13, 1996, response to Generic Letter (GL) 95-07, this temperature is also conservative since it also assumes valve temperature follows the Pressurizer temperature at saturated
- 2 steam conditions and that no heat is retained in the valve during cooldown.
Furthermore, plant operators are especially sensitive to the potential for pressurized thermal shock (PTS) and directed in the EOPs to open the PORV Block Valves early in the accident.
In the February 13, 1996, response, it was stated that the 148°F temperature difference was not large enough to cause the valve to become thermally bound. This was based on engineering judgement, motor-operated valve (MOV) test experience, and past operating history. However, a commitment was made to revise plant operating procedures to reduce this temperature differential.
In correspondence dated June 21, 1996, the NRC requested additional information regarding the proposed procedural changes to reduce the temperature difference on the PORV Block Valves. Question 2 of the NRC request was directed to our planned corrective actions for elimination of susceptibility of the PORV Block Valves to thermal binding. Additional details describing the conditions for opening and closing as well as the description of the planned procedure changes were provided in the Palisades response dated July 22, 1996. It was also acknowledged that revising operating procedures would reduce the operators' ability to operate the plant within the SOP-1 Pressure and Temperature Limit Curve and that Palisades would review alternatives before making any procedure changes. Palisades has performed a review of the proposed procedure changes, alternatives available for the elimination/reduction of thermal binding susceptibility, and the consequences of continued operation in the current configuration.
In addition, a review of NRC responses to GL 95-07 from other Combustion Engineering plants was performed.
Based on these reviews, it is recommended that operating prqcedures not be revised and that the control switch trip for PORV Block Valve motor operators be changed from torque switch closed to limit switch closed. This recommendation is made for the following reasons: 1. The proposed procedure changes would reduce the operators' ability to maneuver within the Primary Coolant System pressure and temperature limit curve. The procedure revision would create an inherent operator work-around and reduce the margin and operator flexibility gained when the plant installed the variable L TOP modification.
- 2. The temperature difference postulated to produce thermal binding is not large and is based on conservative assumptions.
Additionally, the calculated temperatures are conservative since they are derived from system pressures at saturated steam conditions and assume valve temperature follows system temperature.
This assumes that no heat is retained in the PORV or the Pressurizer piping.
- 3 3. Plant operation to achieve the postulated temperature difference does not represent normal operation.
During heatup, L TOP is disabled and the PORV Block Valves closed soon after reaching 460°F. At this point, plant operators normally maintain PCS pressure well within the Pressure and Temperature Limit Curves. Conversely, during cooldown L TOP is enabled early when PCS pressure is still high. The probability of reaching postulated plant conditions for the temperatures required to produce thermal binding is unlikely.
The proposed modification is to change the closed control switch trip from torque closed to limit closed. This would assure that excessive closing forces do not exist on the valve disc when the valve is closed and would reduce the amount of unwedging force required for opening. This corrective action will reduce the susceptibility for thermal binding for the PORV Block Valves. Limit seating is commonly used throughout the industry and is used on the low pressure safety injection (LPSI) Loop Injection MOVs at Palisades.
. -*
- ATTACHMENT 2 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 CHANGE IN COMMITMENTS MADE IN 180-DAY RESPONSE TO GENERIC LETTER 95-07 COMMITMENT 3: PRESSURE LOCKING POTENTIAL IN HPSI PUMP SUBCOOLING ISOLATION VALVES 2 Pages
- * .*. c*oMMltMENT 3: PRESSURE LOCKING POTENTIAL IN HPSI PUMP SUBCOOLING ISOLATION VALVES The purpose of this evaluation is to provide justification to revise the current commitment to modify the valve discs of the HPSI Pump Subcooling Isolation Valves to eliminate the possibility for these valves to become pressure locked. The intent is to achieve the same result by another method. The original commitment was to modify the valve disc by drilling a hole to equalize the pressure between the bonnet and the high side line pressure.
This modification was to be done during the 1998 refueling outage when the core was scheduled to be loaded. This was needed because the modification to the valve discs requires disassembly of the valves. Disassembly of these valves requires draining the header connected to the Shutdown Cooling Heat Exchanger and would render HPSI, Containment Spray, and Shutdown Cooling inoperable.
After the commitment was made, plar:is changed and the core is no longer scheduled to be off-loaded during the 1998 refueling outage. Since full core off-load is no longer scheduled for the 1998 refueling outage, other* options for resolving the pressure_
locking concern were explored.
Implementation of the valve disc modification by the establishment of a freeze seal to provide boundary isolation was considered.
While a freeze seal was possible, the plant staff evaluated the consequences of a freeze seal failure. Such a failure would create a PCS leak outside of containment which could potentially flood a room containing the safety injection and shutdown cooling pumps. The consequences of such a failure create an unacceptable risk, therefore the freeze seal option was not pursued. An additional option considered was an analytical evaluation of the actuator to overcome the pressure locking forces. This was ruled out since there has been no validation testing to date which could justify an analytical approach for these valves. The plant conditions which led to pressure locking of these valves was also examined.
Results of this evaluation confirmed the conditions leading to pressure locking. In addition, no changes to plant procedures were identified that could mitigate all of the conditions leading to pressure locking of these valves. Two procedure changes were recommended and have been implemented which assures the valves do not have pressure trapped in the bonnet after either a LPSI pump or containment spray pump are secured.
- The safest, most feasible optio_n presented has been an alternate modification to eliminate the pressure locking potential.
This alternate modification consists of externally connecting the bonnet, through the existing bonnet leak-off line, to the upstream piping. The connection to the upstream piping would be accomplished by drilling a hole in the upstream piping through a full ported valve. When the pipe wall penetration occurs, water would flow out of the hole and would be isolated by closing the valve. This (commonly called a hot tap) could be done without having to isolate the
. ' *
- upstream piping. Therefore the modification could be performed with the plant on line and Shutdown Cooling secured. This modification would have the same effect as drilling a hole in the upstream disc and would remove the possibility of these valves becoming pressure locked. Special precautions will be taken to prevent detrimental foreign material from entering the line. 2}}