ML18051A414
| ML18051A414 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/05/1983 |
| From: | Dewitt R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML18051A413 | List: |
| References | |
| NUDOCS 8305100287 | |
| Download: ML18051A414 (9) | |
Text
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CONSUMERS POWER COMPANY
. Docket 50-255 Request for Change to the Technical Specifications License DPR-20 For the reasons hereinafter set forth, it is requested that the Technical Specifications contained in the Provisional Operating License DPR-20, Docket 50-255, issued to Consumers Power Company on October 16, 1972, for the Palisades Plant be changed as described in Section I below:
I.
CHANGES A.
Revise Section 4.1.1.a.3 to read as follows:
"Performance of a channel calibration on the PORV actuation channel at least once per refueling cycle."
B.
Replace Table 4. 1.1 with the re vi s~d Table 4.1.1, "Minimum Frequency for Checks, Calibrations and Testing of Reactor Protective System".
C.
Replace Table 4.1. 2 with the revised Table 4.1. 2, "Minimum Frequency for Checks, Calibration and Testing of Engineered Safety Feature Instrumentation Controls".
D.
Replace Table 4.1. 3 with the revised Table 4.1. 3, "Minimum Frequency for Checks, Calibrations and* Testing of Miscellaneous Instrumentation and Controls".
E.
Revise the first sentence of Section 4.7.1.c to read:
".* ',. at least once per refueling cycle during plant shutdown."
F.
Revise the first sentence of Section 4.16.1.c to read as follows:
"At least once per refueling cycle.
G.
Revise the fifth paragraph of Section 4.16.i, Basis, to read:
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" * *
- shutdowns at least once per refueling cycle."
.... *.....J H.
Revise Section 4.17.2.2.d to read:
"At least onc.e per refueling cycle during shutdown*, by... "
I.
Revise Section 4.17.5.1 to read:
"Each of the penetration fire barriers shall be verified to be functional by a visual inspection at least once per refueling cycle and prior to declaring a penetration fire barrier functional following repairs or maintenance."
Revised Technical Specification pages are attached.
Proposed changes are shown by a vertical line in the right-hand margin.
CONSUMERS POWER COJ\\1PANY Docket 50-255 Request for Change to the Technical Specifications License DPR-20 II.
DISCUSSION The above proposed Technical Specifications changes are requested in order to prevent unnecessary plant shutdowns or the extension of outages for the sole purpose of performing Technical Specification Surveillance Tests.
The Palisades Plant Surveillance Test Procedures (STP) identified in Attachment 1 are required to be performed on an 18-month cycle and during a cold shutdown condition.
A few of the tests can be performed at hot. shutdown and power operation; however, it is Consumers Power Company's position that conducting surveillance requirements for critical instrumentation and controls during these plant conditions can impact the safe operation of the plant.
Consumers Pm.rer Company requests that the testing frequency for the STPs identified in Attachment 1 be changed such that these STPs can be performed anytime during each refueling cycle.
An 18-month cycle is insufficient in duration to allow for the performance of Surveillance Testing during refueling outages only, even if the +/-25% criteria is utilized.
The primary reason for this is due to the fuel reload design which was implemented during the 1979-80 refueling outage.
The Palisades Plant was modified from approximately a 7500 Megawatt-Day per ton cycle to approximately a 10,000 Megawatt,...Day per ton cycle.
This has resulted in approximately a five month extension to each fuel cycle.
With the equipment and component problems the Palisades plant experienced in the early stages of the current fuel cycle, the next refueling outage is now tentatively scheduled for August 13, 1983.
This is 23~ months since the beginning of the last refueling outage (September 1980 to January 1981).
The due dates for the STPs listed in Attachment 1 will all occur before the scheduled date of the next refueling outage.
And in most cases, the
+/-25% criteria will also be utilized prior to the next refueling outage.
In order to perform these STPs when they are due, we would.have to bring the plant down to a condition required to run the STPs.
Putting the reactor through a shutdown transient just to perform these STPs is not considered justifiable.
Consumers Power Company has reviewed the results of the last three surveillance tests performed on the instrumentation and controls identified in Attachment 1 and determined that all of the systems or components were operable.
In addition, the deviation and event reports generated as a result of these tests did not indicate any trends for potentially reoccuring systematic problems.
It is our position that permitting the surveillance testing intervals to be dependent on the length of the fuel cycle will not jeop~rdize the plant nor the health and safety of the public.
The testing frequency proposed by this submittal is consis-tent with the testing frequencies stated in Consumers Power Company's letters dated August 30, 1982 and November 5, 1982 entitled "Proposed Technical Specifications Request - Engineered Safety Feature Filtration System".
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III. CONCLUSION Based on the foregoing, the Palisades Plant Review Cmmittee has reviewed this change and found it acceptable.
Also the Nuclear Activities Plant Organization has reviewed the change under the cognizance of the Nuclear Safety Board and found it acceptable.
CONSUMERS POWER COMPANY BY ~];~i!H!e;/f Nuclear Operations Sworn and subscribed to before me this 5th day of May 1983.
My commission expires on 11/5/86.
SHERRY LYNN DURFEY Notary Pu~li~, Jackson County, ~~le,,
My Cornrn1ss1on Expires Nov. 5, 1986 MI0583-0008A-NL02
TECHNICAL SPECIFICATION "(T/S)
SURVEILLANCE PROCEDURES Refueling Calibration of PCS Overpressure Protection PCS Power Operated Relief Valves Safety Channel Linear Power Drawer Calibration Reactor Coolant Flow Channels Calibration Thermal Margin/Low Pressurizer Pressure Channels Calibration High-Pressurizer Pressure Channels Calipration Steam Generator Level TS0483-0001A-NL02 APPLICABLE T/S SECTIONS 4.1.1.a.2 4.1.1.a.4 Table 4.1.1.1.d Table 4.1.1.3.b Table 4. 1.. 1. 4. b Table 4.1.1.5.b Table.4.1.1.6.b ATTACHMENT 1 LAST 3 TIMES TEST WAS PERFORMED
. 2/9/801 9/14/81 12/4/79.
11/2/81 11/09/81 1/19/79.
5/19/80 9/1/81 4/10/78 9/26/79 9/16/81 9/16/79 11/2/80 9/ 10/81 4/ 11/78 9/17/79 9/14/81 4/10/78 11/29/79 11/12/81 1
First Time Test Was Performed EQUIPMENT OPERABLE OR PARAMETER MEETS THE APPLICABLE T/S SECTIONS Yes.
Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes
. Yes Yes Yes Yes Yes Yes Yes Page 1 9f 6 REMARKS (Significant Deviation and Event Reports Generat~d as a Result of the Tests)
DR-PAL-78-013/3'Trip setpoints out of tolerance in the conservative direction DR-PAL-78-029/Instrument drift -
A periodic activity control sheet written to increase surveillance DR-PAL-80-089.~
The age of PT-:Ol02D caused normal instrument drift DR-PAL-78-035/Instrument drift of LT-0752B app~rent zero shift of-1.5%~ Past tests do not show any*systematic negative shift.
DR-PAL-81-188/
Several instruments were found out of specified tolerances incorporated into lastest test revision.
TECHNICAL SPECIFICATION (T/S)
SURVEILLANCE PROCEDURES Low-Pressure SIS Initiation Logic Engineered Safeguards System Containment Area Monitor Calibration Containment High Radiation Test Containment High-Pressure Spray System Tests APPLICABLE T/S SECTIONS Table 4.1.2.1.b Table 4.1.2.2.a Table 4.1.2.3.b Table 4.1.2.6.a Table 4.1.2.11.b Table L
4.1.2.5.b2 Table 4.1.3.4.b Table 3
4.1.2.5.d3 Table 4.1.2.7.a3 Table 4.1.2.7.b Table 4.1.2.4.b Table 4.2.2.b Table 4.2.2.13.c 4.6.1.a 4.6.5.a 4.7.1.b ATTACHMENT 1 LAST 3 TIMES TEST WAS PERFORMED 3/2/78 9/21/.79 9/20/81 4/8/78 5/7 /80 12/21/81 4/26/78 11/7 /79 4/29/81 4/15/78 5/3/80 11/28/81 4/2/78 4/27/80 11/30/81 EQUIPMENT OPERABLE OR PARAMETER MEETS THE APPLICABLE T/S SECTIONS Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes
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Page 2 qf 6 REMARKS (Significant Deviation and Eyeht Reports Generated as a Result of the Tests.)
DR-PAL-80-091/Whole system operated as it was designed to except the B charging
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pump did not sta*rt on by-paP flow.
Test results only pertain to the Containment Isolation Monitors.
The Containment High Range Monitors have not been declared operational.
The 4/27/80 test had to be performed twice.
CV-0437A and CV-043B failed to open because the testors did not A wait long enough for the ti~
delay to'time out. This portion of the test was re-run and valves operated satisfactorily.
Also, the right channel SIS alarm did not function properly however, the alarm serves no safety function.
2 This section was changed to 4.1.3.4.a.b and 4.1.3.4.b.b by our T/S Change Request dated 11/5/82.
3 This section was changed to 4.1.3.4.b.d by our T/S Change Request dated 11/5/82.
TS0483-0001A-NL02
TECHNICAL SPECIFICATION (T/S)
SURVEILLANCE PROCEDURES SIRW Tank Level Switch Interlocks Test Safety Injection Tank Pressure Channel Calibration Safety Injection Tank Pressure Switch Calibration Safety Inject;i.on Tank Level/Channel Calibration Main Steam Isolation Valve Circuit Test SIRW Tank Temperature Indicator Calibration TS0483-0001A-NL02 APPLICABLE T/S SECTIONS Table 4.1.2.12 Table 4.1.2.13.b Table 4.1.2.13.b Table 4.1.2.13.b Table 4.1.2.16.b Table 4.1.2.17.b ATTACHMENT 1 LAST 3 TIMES TEST WAS PERFORMED 2/28/78 5/6/80 9/22/81 9/ 16/79 12/1/80 12/5/81 9/16/79 11/11/80 9/15/81 9/16/79 12/4/80 12/22/81 4/1/78 3/14/80 12/6/81 8/ 1/79 11/5/80 9/1/81 EQUIPMENT OPERABLE OR PARAMETER MEETS THE APPLICABLE T/S SECTIONS Yes Yes Yes Yes Yes Yes with exceptions Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes r
.Page 3 o.f 6 REMARKS (Significant Deviation and Event Reports Generated as a Result of the Tests.)
DR-80-214/Equipment operable but "as found" values were slightly over tolerance. It was dee~
appropriate to change the T/S Surveillance Test.
During the 1981 refueling outage, not all of the test data met the acceptance criteria, however, major modifications were well under way in pan~l C-13.
DR-PAL-79-125/Level indications and alarms out of tolerance.
Alarm settings drifted in t.
conservative direction.
TECHNICAL SPECIFICATION (T/S)
SURVEILLANCE PROCEDURES Control Rod Calibration Pressurizer Level Channel Calibration Control Rod Drive System Interlocks Automatic Rod Withdrawal Prohibit Interlock Matrix Steam Generator Feedwater Flow Instrument Loop Calibration TS0483-0001A-NL02 APPLICABLE T/S SECTIONS Table 4.1.3.2.c Table 4.1.3.3.c Table 4.1.3.7.b Table 4.1.3.8.a Table 4.1.3.8.b Table 4.1.3.8.a Table 4.1.3.8.5 Table 4.1. 3.10 ATTACHMENT 1 LAST 3 TIMES TEST WAS PERFORMED 3/17/78 1/20/80 11/20/81 10/2/79 12/9/80
. 9/19/81 12/18/81 5/9/82 8/ 13/82 12/5/81 5/11/82 8/11/82 9/13/79 11/9/80 9/20/81 EQUIPMENT OPERABLE OR PARAMETER MEETS THE APPLICABLE T/S SECTIONS Yes Yes Yes Yes Yes Yes Yes Yes Yes with exceptions Yes Yes Yes Yes Yes Yes Page 4 of 6 REMARKS (Significant Deviation and Everit Reports Generated as a Result of the Tests.)
DR-PAL-78-019/Transmitter drifted causing a 1-2% error. Past
- history shows drift limited
__,2%. No further action taken.
DR-PAL-81-008/The acceptance
~riteria is violated for "as found" values on some of the units because of compensation incorporated to allow for static working pressure calibration shifts.
DR-PAL-82-120/The automatic and withdrawal prohibit alarm did not occur or reset within the proper tolerance, however, auto rod motion is administra-tively prohibited.
TECHNICAL SPECIFICATION (T/S)
SURVEILLANCE PROCEDURES Containment Humidity Narrow Range Pressure Indication/Shutdown Cooling
- Line Interlock Calibration Containment Service Water Break Detector Subcooled Margin Monitor Surveillance Containment Hydrogen Diesel Gene4a§or Inspection Function Test Seismic Hydraulic Restraints 4
TWo surveillance procedures.
APPLICABLE T/S SECTIONS Table 4.1.3.11 Table 4.1.3.12 Table 4.1.3.13 Table 4.1.3.18.b Table 4.1.3.22.b 4.7.1.c 4/16/1 ATTACHMENT 1 LAST 3 TIMES TEST WAS PERFORMED 9/22/79 11/11/80 11/19/81 10/9/79 11/21/80 9/11/81 9/10/79 1/21/81 11/16/81 12/7/811 EQUIPMENT OPERABLE OR PARAMETER MEETS
- THE APPLICABLE T/S SECTIQNS Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Has not been performed 10/21/81, 11/20/811 Yes 10/2/81, 11/8/81 Yes 3/8/78 Yes 3/5/80 Yes 11/27 /81 Yes 5
The inspections are routinely performed in the Preventative Maintenance Program.
TS0483-0001A-NL02 I
Page 5 of 6 REMARKS (Significant Deviation and Event Reports Generated as a Result of the Tests.)
DR-PAL-79-123/HT-1812 failed; transmitted, repaired and re-calibrated.
HT-1813, 1814 and 1815 tubes replaced following 11/11/80 test.
e DR-PAL-81-009/Equipment was operable but out of calibration.
It required a larger differ-ential pressure to actuate alarm.
e
TECHNICAL SPECIFICATION (T/S)
SURVEILLANCE PROCEDURES Inspection and Preventive Maintenance of Fire Pump Diesels Penetration Fire Barriers Surveillance TS0483-0001A-NL02 APPLICABLE T/S SECTIONS 4.17.2~2.d 4.17.5.1 ATTACHMENT 1
.LAST 3 TIMES TEST EQUIPMENT OPERABLE WAS PERFORMED OR PARAMETER MEETS 10/10/79 5/7 /80 12/6/81 4/18/801 12/15/81
- THE APPLICALBE T/S SECTIONS Yes Yes Yes Yes with exceptions Yes with exceptions Page 6 o.f 6 REMARKS (Significant Deviation and Event Reports Generated as a result of the Tests.)
ER-080-018/During inspection of fire barriers bottom side of penetration H0-12 was missi~
The penetrations were open for modification~ in progress -
A fire watch was stationed.
(