ML18051A414

Application for Amend to License DPR-20,changing Tech Specs to Allow Surveillance Tests That Require Cold Shutdown Conditions to Be Performed on Refueling Cycle Rather than Current 18-month Cycle

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: ML18051A412 ML18051A414 ML18051A415
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:

~

!;* . .. " * *

• shutdowns at least once per refueling cycle."

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 .

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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".

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

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Page 1 9f 6 ATTACHMENT 1 TECHNICAL SPECIFICATION "(T/S) APPLICABLE T/S LAST 3 TIMES TEST EQUIPMENT OPERABLE OR REMARKS SURVEILLANCE PROCEDURES SECTIONS WAS PERFORMED PARAMETER MEETS THE (Significant Deviation and Event APPLICABLE Reports Generat~d as a Result of T/S SECTIONS the Tests)

Refueling Calibration of 4.1.1.a.2 . 2/9/80 1 Yes.

PCS Overpressure Protection 9/14/81 Yes PCS Power Operated 4.1.1.a.4 12/4/79. Yes Relief Valves 11/2/81 11/09/81 Yes Safety Channel Linear Table 4.1.1.1.d 1/19/79. Yes Power Drawer Calibration 5/19/80 Yes 9/1/81 Yes Reactor Coolant Flow Table 4.1.1.3.b 4/10/78 Yes DR-PAL-78-013/3'Trip setpoints Channels Calibration 9/26/79 Yes out of tolerance in the 9/16/81 conservative direction  ;

Thermal Margin/Low Table 4. 1.. 1. 4. b 9/16/79 Yes Pressurizer Pressure 11/2/80 Yes Channels Calibration 9/ 10/81 . Yes High-Pressurizer Pressure Table 4.1.1.5.b 4/ 11/78 Yes DR-PAL-78-029/Instrument drift -

Channels Calipration 9/17/79 Yes A periodic activity control 9/14/81 Yes sheet written to increase surveillance DR-PAL-80-089.~

The age of PT-:Ol02D caused normal instrument drift Steam Generator Level Table .4.1.1.6.b 4/10/78 Yes DR-PAL-78-035/Instrument drift 11/29/79 Yes of LT-0752B app~rent zero 11/12/81 Yes 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.

TS0483-0001A-NL02 1

First Time Test Was Performed

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Page 2 qf 6 ATTACHMENT 1 TECHNICAL SPECIFICATION (T/S) APPLICABLE T/S LAST 3 TIMES TEST EQUIPMENT OPERABLE REMARKS SURVEILLANCE PROCEDURES SECTIONS WAS PERFORMED OR PARAMETER MEETS (Significant Deviation and Eyeht THE APPLICABLE Reports Generated as a Result of T/S SECTIONS the Tests.)

Low-Pressure SIS Table 4.1.2.1.b 3/2/78 Yes Initiation Logic Table 4.1.2.2.a 9/21/.79 Yes 9/20/81 Yes Engineered Safeguards Table 4.1.2.3.b 4/8/78 Yes DR-PAL-80-091/Whole system System Table 4.1.2.6.a 5/7 /80 Yes operated as it was designed Table 4.1.2.11.b 12/21/81 Yes to except the B charging ~

pump did not sta*rt on by-paP flow.

L Containment Area Table 4.1.2.5.b2 4/26/78 Yes Test results only pertain to the Monitor Calibration Table 4.1.3.4.b 11/7 /79 Yes Containment Isolation Monitors.

4/29/81 Yes The Containment High Range Monitors have not been declared operational.

3 Containment High Table 4.1.2.5.d3 4/15/78 Yes Radiation Test Table 4.1.2.7.a 5/3/80 Yes 3

Table 4.1.2.7.b 11/28/81 Yes Containment High- Table 4.1.2.4.b 4/2/78 Yes The 4/27/80 test had to be Pressure Spray Table 4.2.2.b performed twice. CV-0437A System Tests Table 4.2.2.13.c 4/27/80 Yes and CV-043B failed to open 4.6.1.a because the testors did not A 4.6.5.a 11/30/81 Yes wait long enough for the ti~

4.7.1.b 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.

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.Page 3 o.f 6 ATTACHMENT 1 .-

TECHNICAL SPECIFICATION (T/S) APPLICABLE T/S LAST 3 TIMES TEST EQUIPMENT OPERABLE REMARKS SURVEILLANCE PROCEDURES SECTIONS WAS PERFORMED OR PARAMETER MEETS (Significant Deviation and Event THE APPLICABLE Reports Generated as a Result of T/S SECTIONS the Tests.)

SIRW Tank Level Table 4.1.2.12 2/28/78 Yes Switch Interlocks Test 5/6/80 Yes 9/22/81 Yes Safety Injection Tank Table 4.1.2.13.b 9/ 16/79 Yes DR-80-214/Equipment operable but Pressure Channel Calibration 12/1/80 Yes "as found" values were slightly 12/5/81 Yes with exceptions 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.

Safety Injection Tank Table 4.1.2.13.b 9/16/79 Yes Pressure Switch Calibration 11/11/80 Yes 9/15/81 Yes Safety Inject;i.on Tank Table 4.1.2.13.b 9/16/79 Yes DR-PAL-79-125/Level indications Level/Channel Calibration 12/4/80 Yes and alarms out of tolerance.

12/22/81 Yes Alarm settings drifted in conservative direction. t.

Main Steam Isolation Table 4.1.2.16.b 4/1/78 Yes Valve Circuit Test 3/14/80 Yes 12/6/81 Yes SIRW Tank Temperature Table 4.1.2.17.b 8/ 1/79 Yes Indicator Calibration 11/5/80 Yes 9/1/81 Yes TS0483-0001A-NL02

Page 4 of 6 ATTACHMENT 1 TECHNICAL SPECIFICATION (T/S) APPLICABLE T/S LAST 3 TIMES TEST EQUIPMENT OPERABLE REMARKS SURVEILLANCE PROCEDURES SECTIONS WAS PERFORMED OR PARAMETER MEETS (Significant Deviation and Everit THE APPLICABLE Reports Generated as a Result of T/S SECTIONS the Tests.)

Control Rod Calibration Table 4.1.3.2.c 3/17/78 Yes Table 4.1.3.3.c 1/20/80 Yes 11/20/81 Yes ,,-

Pressurizer Level Table 4.1.3.7.b 10/2/79 Yes DR-PAL-78-019/Transmitter drifted Channel Calibration 12/9/80 Yes causing a 1-2% error. Past *

. 9/19/81 Yes 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.

Control Rod Drive Table 4.1.3.8.a DR-PAL-82-120/The automatic System Interlocks Table 4.1.3.8.b 12/18/81 Yes and withdrawal prohibit alarm 5/9/82 Yes did not occur or reset within 8/ 13/82 Yes with exceptions the proper tolerance, however, auto rod motion is administra-tively prohibited.

Automatic Rod Withdrawal Table 4.1.3.8.a 12/5/81 Yes Prohibit Interlock Matrix Table 4.1.3.8.5 5/11/82 Yes 8/11/82 Yes Steam Generator Feedwater Table 4.1. 3.10 9/13/79 Yes Flow Instrument Loop 11/9/80 Yes Calibration 9/20/81 .,

Yes TS0483-0001A-NL02

I Page 5 of 6 ATTACHMENT 1 ,*

TECHNICAL SPECIFICATION (T/S) APPLICABLE T/S LAST 3 TIMES TEST EQUIPMENT OPERABLE REMARKS SURVEILLANCE PROCEDURES SECTIONS WAS PERFORMED OR PARAMETER MEETS * (Significant Deviation and Event THE APPLICABLE Reports Generated as a Result of T/S SECTIQNS the Tests.)

Containment Humidity Table 4.1.3.11 9/22/79 Yes DR-PAL-79-123/HT-1812 failed; 11/11/80 Yes transmitted, repaired and re-11/19/81 Yes calibrated. HT-1813, 1814 and 1815 tubes replaced following 11/11/80 test.

Narrow Range Pressure Indication/Shutdown Cooling

• Line Interlock Calibration Table 4.1.3.12 10/9/79 11/21/80 9/11/81 Yes Yes Yes e

Containment Service Table 4.1.3.13 9/10/79 Yes Water Break Detector 1/21/81 Yes DR-PAL-81-009/Equipment was 11/16/81 Yes operable but out of calibration.

It required a larger differ-ential pressure to actuate alarm.

Subcooled Margin 1 Table 4.1.3.18.b 12/7/81 Yes Monitor Surveillance Containment Hydrogen Table 4.1.3.22.b Has not been performed 1

Diesel Gene4a§or 4.7.1.c 10/21/81, 11/20/81 Yes Inspection ' 10/2/81, 11/8/81 Yes e Function Test Seismic 4/16/1 3/8/78 Yes Hydraulic Restraints 3/5/80 Yes 11/27 /81 Yes 4

TWo surveillance procedures.

5 The inspections are routinely performed in the Preventative Maintenance Program.

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Page 6 o.f 6 ATTACHMENT 1 TECHNICAL SPECIFICATION (T/S) APPLICABLE T/S .LAST 3 TIMES TEST EQUIPMENT OPERABLE REMARKS SURVEILLANCE PROCEDURES SECTIONS WAS PERFORMED OR PARAMETER MEETS (Significant Deviation and Event

• THE APPLICALBE Reports Generated as a result of T/S SECTIONS the Tests.)

Inspection and Preventive 4.17.2~2.d 10/10/79 Yes Maintenance of Fire 5/7 /80 Yes Pump Diesels 12/6/81 Yes Penetration Fire Barriers 1 4.17.5.1 4/18/80 Yes with exceptions ER-080-018/During inspection of Surveillance fire barriers bottom side of penetration H0-12 was missi~

12/15/81 Yes with exceptions The penetrations were open for modification~ in progress -

A fire watch was stationed. (

TS0483-0001A-NL02