ML18051B445

Supplemental Application for Amend to License DPR-20, Revising Tech Specs to Require Quarterly Flow Testing of Automatic Feedwater Sys

ML18051B445
Person / Time
Site:	Palisades
Issue date:	06/21/1985
From:	Bordine T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Office of Nuclear Reactor Regulation
Shared Package
ML18051B446	List: ML18051B445 ML18051B447
References
NUDOCS 8506250472
Download: ML18051B445 (3)

Text

consumers Power

-company General Offices: 1945 West Parnell Road, Jackson, Ml 49201 *:(5171766-0550 June 21, 1985

Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

ADDITIONAL INFORMATION - PROPOSED TECHNICAL SPECIFICATION CHANGE REQUEST - AUXILIARY FEEDWATER SYSTEM PUMP DISCHARGE VALVES By letter dated May 31, 1985 Consumers Power Co requested a change to the Palisades Plant Technical Specifications to reduce the frequency of Auxiliary Feedwater (AFW) System flow testing. The purpose of the change was to reduce the thermal cycling of the AFW inlet nozzles on the steam generators by flow testing each 18 months as allowed by Standard Technical Specifications rather than monthly. In addition, it was planned to submit a request for relief from ASME B&PV Code Section XI to change the frequency for flow testing of several AFW check valves from quarterly to 18 months so as to take full advantage of the proposed Technical Specification Change. However, based on our Nuclear Safety Board's review of the proposed change, it has been decided that this request for relief wi_ll not be submitted at this time. The net effect of this decision, assuming your approval of the proposed Technical Specification change, would be to require quarterly flow testing of the AFW system. This decision will be reconsidered if new information becomes available. The Nuclear Safety Board's decision to require flow testing on a quarterly basis is discussed below.

Our Nuclear Safety Board has concluded that an 18 month flow test frequency for the'AFW system may not be optimum. Since- the AFW lines are used for normal startups and shutdowns, thermal cycling from testing represents only a portion of the total number of cycles experienced by _the nozzles. The incremental change in .the number of cycles experienced due to a change in test frequency from the current ASME B&PV requirements of quarterly to 18 months is small compared to the total number of cycles expected to be experienced during normal startups and shutdowns. Futhermore, the impact of changes which increase surveillance intervals for standby components can be equated to a reduction in confidence in the operability of the component since increased testing intervals result in increased time during which the status of the component is unknown. On the basis of engineering judgment and the partially completed Probabilistic Risk Assessment (PRA) for Palisades Plant, it is 62 1--9=_5=0..6r;;2~50~.4r.7~2tAg50~50oQ~

21~-=-5=-5--11 OC0685-0226-NL04 PDR ADOCK PDR p

Director, Nuclear Reactor Regulation 2 Palisades Plant TSCR Auxiliary Feedwater System June 21, 1985 concluded that the ISI Code requirements for quarterly flow testing of the AFW system is optimum. This frequency will significantly reduce the thermal cycling,due to testing from the current monthly requirement without substantially reducing assurance of continuing AFW system operability through flow testing.

• Although the Technical Specification change submitted May 31, 1985 permits AFW discharge valve flow testing at an 18 month surveillance interval, existing Technical Specification 4.3.c r~quires compliance with the ASME B&PV Code.

Relief requests from the quarterly flow test requirements will not be submitted until adequate Palisades Plant specific data is assembled to assure AFW system reliability is maintained. However, your review and approval of our May 31, 1985 change remains as requested with the following two additional administrative clarifications:

Add the word "auxiliary" to specification 4.9 so that it reads:

"Demonstrate the operability of each auxiliary feedwater pump:"

Add the steam valve control number "CV-0522B" to specification 4.9.b.2 so that it reads:

"2~ Verifying that each pump breaker (or steam valve control for CV-0522B) receives an actuation signal upon receipt of an auxiliary feedwater actuation test signal.-"

A revised Proposed Technical Specification page is attached. The revised attached page 4-45 along with page 4-lla provided with our May 31, 1985 submittal supersede the same pages included with our previous Technical Specification Change Request dated September 17, 1984. The remaining pages 3-32, 3-38, 3-38a, 3-39, 3-81a, and .4-39 remain as proposed' in the September 17, 1984 submittal.

It should be noted that neither the September: 17, 1984 nor the May 31, 1985 Proposed Technical Specification Change Request addresses the "PWR Model Technical Specifications for NUREG-0737 TMI-2 Lessons Learned" requirement 4.7.1.3 included as Enclosure 3 to Generic Letter No. 83-37. The surveillance requirement *specifies the following:

"4.7.1.3** An auxiliary feedwater flowpath shall be demonstrated to be available prior to startup after any refueling outage or other cold shutdown of longer than 30 days by utilizing an auxiliary feedwater pump toIL pump water from the normal water source to the steam generators]~

• • This is applicable only for plants that do not use auxiliary feedwater for startup/normal shutdown."

The auxiliary feedwater train for pumps P-8A and P-8B is normally used ~uring startup and normal shutdown. Although the auxiliary feedwater train for pump OC0685-0226-NL04

Director, Nuclear Reactor Regulation 3 Palisades Plant TSCR Auxiliary Feedwater System June 21, 1985 P-8C is not normally used during startup/normal shutdowns because the train does not have a tie for hydrazine chemical addition, it can and has been used.

The system description submitted with our auxiliary feedwater modification system evaluation (reference our letter dated November 2, 1981) specifies that "either of the motor-driven pumps (existing or the new one) can be used during normal startup, and shutdown modes of operation." Furthermore, compliance with the quarterly flow test requirements of the ASME B&PV Code Section XI for all the auxiliary feedwater trains satisfies the intent of the "PWR Model Technical Specifications". Thus it is our conclusion that the additional surveillance requirement specified in Section 4.7.1.3 of the model is unnecessary.

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-- - Thomas- C Bordine Staff Licensing Engineer CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector - Palisades Attachment OC0685-0226-NL04