ML18052B471

Forwards Response to SER on Util Response to Generic Ltr 82-33 Re Conformance to Reg Guide 1.97,justifying Deviation from Reg Guide 1.97 Guidance & Providing Proposed Implementation Schedule

ML18052B471
Person / Time
Site:	Palisades
Issue date:	01/22/1988
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
RTR-REGGD-01.097, RTR-REGGD-1.097 GL-82-33, NUDOCS 8801270574
Download: ML18052B471 (6)

Text

consumers Power Kenneth W Berry POWERIN& Director MICHlliAN'S PROliRESS Nuclear Licensing General Offices: 1945 West Parriall Road, Jackson, Ml 49201 * (517) 788-1636 January 22, 1988 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

RESPONSE SAFETY EVALUATION REPORT - CONFORMANCE TO REGULATORY GUIDE 1. 97 By a letter dated October 20, 1987, the NRC provided the staff's Safety Evaluation Report (SER) on Consumers Power Company's response to Generic Letter 82-33, Conformance to Regulatory Guide 1.97. A copy of the Technical Evaluation Report, prepared by EG&G, Idaho Inc. was also attached. The SER stated that Consumers Power Company conforms to or had acceptably justified deviations from the guidance of R. G. 1.97 for each post-accident monitoring variable with the exception of the variables for accumulator tank *1evel and pressure, quench tank temperature and pressure, steam generator pressure, and component cooling water flow to the ESF system. The SER noted that the acceptability of instrumentation for accumulator tank level and pressure was the subject of a generic review by the NRC staff and would remain open until the completion of that review. However, for the remaining items for which the staff found that Consumers Power Company had not provided adequate justification, the SER requested that Consumers Power Company respond to the staff positions within 45 days. The SER also noted', "An appropriate implementation schedule will be developed by the project manager via discussion with the licensee."

During a November 10, 1987 conference call between Consumers Power Company staff, the NRC Palisades Project Manager and other NRC staff personnel, we noted that neither the SER nor the TER addressed the adequacy of our justifications for not providing instrumentation to monitor these variables.

We requested that the staff provide clarification with regard to the rejection of our justifications for not meeting the requirements of Regulatory Guide 1.97 as specified in our September 13, 1983 and April 30, 1986 letters.

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, e Nuclear Regulatory Commission 2 Palisades Nuclear Plant Conformance to Regulatory Guide-1.97 January 22, 1988 It was agreed during the conference call that the staff would provide the information requested. It was also agreed that Consumers Power Company's response to the staff positions stated in the SER would be delayed until after the receipt of the additional information from this NRC.

This information was provided by the NRC in a subsequent conference call on December 8, 1987. During that call, Consumers Power Company agreed to provide a response to the staff positions given in the SER for those Regulatory Guide 1.97 items where the staff found that Consumers Power Company was not justified in deviating from the guidance of R. G. 1.97 *. Attachment 1 to this letter provides that response and a proposed implementation schedule.

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Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, NRC NRC Resident Inspector - Palisades OC0188-003S-NL01

ATTACHMENT Consumers Power Company

• Palisades Plant Docket 50-255 RESPONSE TO SAFETY EVALUATION REPORT -

CONFORMANCE TO REGULATORY GUIDE 1.97 January 22, 1988 3 Pages OC0188-003S-NL01

1 Response to Safety Evaluation Report -

Conformance to Regulatory Guide 1.97 NRC Staff Position - Accumulator Tank Level and Pressure In TER Section 3.3.1 and Appendix A Item I, EG&G concluded that for the vari-ables accumulator tank level and pressure, the licensee should designate either level or pressure as the key variable to directly indicate accumulator discharge and provide instrumentation for that variable that meets the requirements of 10CFRS0.49. The staff, however, is currently generically reviewing the need for environmentally qualified Category 2 instruments to monitor accumulator tank level and pressure. We will therefore report on the acceptability of this item when the generic review process is complete.

CPCo Response Consumers Power defers responding to this item pending receipt of the NRC generic review.

NRC Staff Position - Quench Tank Temperature Regulatory Guide 1.97 recommends instrumentation with a temperature range of 50 to 750°F to monitor the quench tank temperature *. The licensee has provided.

instrumentation for this variable with a range of 0 to 300°F. The licensee states that the tank is provided with a rupture disk to relieve an overpressure condition at the tank design pressure. The licensee further states that the only event which could result in excessive temperatures would be a stuck open safety relief valve.

The staff finds this justification unacceptable. The licensee should install instrumentation that will remain functional and on scale, including the maximum expected saturation temperature, during a~y accident that lifts the pressurizer safety or.relief valves.

CPCo Response Consumers Power will provide instrumentation for monitoring quench tank temperature having a range which extends to the saturation temperature corresponding to the pressure setting of the quench tank rupture disk. This temperature is the maximum expected temperature during any accident that lifts the pressurizer safety or relief valves. Modifications required to meet the specified temperature range will be completed by the end of the second refueling outage from now, currently scheduled for early 1990.

NRC Staff Position - Quench Tank Pressure Regulatory Guide 1.97 recommends instrumentation with a pressure range of 0 to design pressure to monitor the quench tank pressure. The licensee has OC0188-003S-NL01

2 provided instrumentation for this variable with a range of 0 to 25 psig. The licensee has acknowledged that the tank's design pressure is 100 psig. The licensee states that the tank is provided with a rupture disk to relieve an overpressure condition at the tank design pressure of 100 psig.

The staff finds this justification unacceptable. The licensee should install instrumentation that will remain functional and on scale, during any accident that lifts the pressurizer safety or relief valves.

CPCo Response Consumers Power will provide instrumentation for.monitoring quench tank pressure having a range which extends to value of the rupture disk setpoint.

This pressure is the maximum expected during any accident which lifts the pressurizer safety or relief valves. Modifications required to meet the specified pressure range will be completed by the end of the second refueling outage from now, currently scheduled for early 1990.

NRC Staff Position - Stearn Generator Pressure Regulatory Guide 1.97 recommends instrumentation with a range of 0 to 20 percent above the lowest safety valve setting to monitor the steam generator pressure. The licensee has provided instrumentation for this variable with a range of 0 to 1000 psig. The upper value of this range is 1.5 percent above the lowest safety valve setting and less than the highest safety valve setting of 20 percent above the lowest safety valve setting as recommended by the regulatory guide.

The staff finds this justification unacceptable. The* licensee should increase the rarige of the instrumentation for this variable to 20 percent above the lowest safety valve setting.

CPCo Response In accordance with the recommendations of Regulatory Guide 1.97, Consumers Power will provide instrumentation for monitoring "steam generator pressure having a range which extends to 20% above the lowest safety valve setpoint.

Modifications to the existing steam generator pressure instrumentation loops required to meet the specified range will be completed by the end of the second refueling outage from now, currently scheduled for early 1990.

NRC Staff Positipn - Component Cooling Water Flow to ESF System Regulatory Guide 1.97 recommends instrumentation be provided to monitor the cooling water flow to ESF system. The licensee has not provided instrumentation to monitor this variable. The licensee states that the proper operation of this system can be determined by monitoring component OC0188-003S-NL01

.,, ..

3 cooling water pump status and the status of the valves that are required to be open.

The staff finds this justification unacceptable. The instrumentation proposed by the licensee will not determine proper system operation should flow blockage or pipe rupture occur. The licensee should provide component cooling water flow to ESF system instrumentation as recommended by Regulatory Guide 1.97.

CPCo Response The Palisades Component Cooling Water system (CCW) has instrumentation in the control room in addition to pump and valve status indications which are used to monitor performance of the CCW system. CCW parameters monitored in the control room include: CCW pump current, CCW pump discharge pressure, CCW surge tank level and shutdown cooling heat exchanger inlet and outlet temperature (CCW side). These parameters are sufficient to allow determination of events such as flow blockage or pipe rupture. Flow blockage events, resulting in decreased system flow, would be ~ndicated by increased CCW pump discharge pressure, decreased CCW pump current and increased differential temperatures across the shutdown cooling heat exchangers. Pipe rupture events would be indicated by decreasing levels in the CCW surge tanks.

Consumers Power considers that the above noted parameters monitored in the control room provide information on the operation of the CCW system which exceeds that which would be obtained by monitoring only CCW flow. Based on the capability of the existing instrumentation to adequately monitor CCW system operation, CCW flow will not be provided.

To reiterate, Palisades monitors the following parameters in the control room in lieu of monitoring CCW flow:

1. ~CW Pump Discharge Pressure

2. CCW Pump Current

3. CCW Surge Tank Level

4. CCW Heat Exchanger Outlet Temperature (SDC Heat Exchanger Inlet)

5. Shutdown Cooling Heat Exchanger Outlet Temperature These instrument loops meet all of the Regulatory Guide 1.97 Category 2 requirements with the exceptions that Items 1, 4 and 5 have transmitters located in a harsh environment which have not been environmentally qualified.

Consumers Power will replace the CCW discharge pressure transmitter and the shutdown cooling heat exchanger ou~let temperature RTD's with environmentally qualified components by the end of the second refueling outage from now, currently scheduled for early 1990. The CCW heat exchanger outlet temperature RTD is being replaced with environmentally qualified components during the next refueling outage based on our earlier commitment to upgrade component cooling water temperature to ESF system.

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