ML18052A801

Proposed Tech Specs Re Diesel Pump Operability & Svc Water Temp

ML18052A801
Person / Time
Site:	Palisades
Issue date:	12/02/1986
From:	CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML18052A795	List: ML18052A794 ML18052A800 ML18052A801
References
NUDOCS 8612100103
Download: ML18052A801 (20)

Text

ATTACHMENT 1 Consumers Power Company Palisades Plant Docket 50-255 PROPOSED TECHNICAL SPECIFICATION PAGE CHANGES eb12100103 061202.

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AT1186-0192-NL02 December 2, 1986 5 Pages

3.4 CONTAINMENT COOLING

. 3.4.1 Applicability Applies to the operating status of the containment cooling systems.

Objective To assure operability of equipment required to remove heat from the containment in normal operating and emergency situations.

Specifications Containment Cooling Systems The primary coolant system shall not be heated above 325°F unless all the following conditions are met:

a.

The following equipment associated with diesel generator 1-2 is operable:

Containment Air Cooler Containment Air_Cooler Containment Air Cooler Service Water Pump Service Water Pump Containment Spray Pump Component Cooling Water Pump VIA V2A V3A P7A P7C P54A P52B

b.

The following equipment associated with diesel generator 1-1 is operable:

c.

d.

Service Water Pump Containment Spray Pump Containment Spray Pump Component Cooling Water Pump Component Cooling Water Pump Diesel Fire Pump Diesel Fire Pump P7B P54B P54C P52A P52C K5/P9B Kl0/P41 The service water inlet temperature is less than or equal to 53°F.

Both containment spray headers are filled to a level greater than the 735-foot elevation.

3-34 Proposed I Proposed 11/24/8011 TSP1186-0163-NL04 11 I

I II

3.4 3.4.2 3.4.3 3.4.4 3.4.5 3.4.6 CONTAINMENT COOLING (Cont'd)

During power operating, one of the components listed in Specification 3.4.1 above may be inoperable provided that the corresponding redundant components shall be tested to demonstrate operability.

If the inoperable component is not restored to operability within 7 days, the reactor shall be placed in a hot shutdown condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

If the inoperable component is not restored to operability within an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the reactor shall be placed in a cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

During power operation, the requirements of Specification 3.4.1 may be modified to allow a total of two of the components listed in Section 3.4.la orb to be inoperable at any one time provided the emergency diesel connected to the opposite engineered safeguards bus is started to demonstrate operability.

The redundant component or system on the other bus shall be tested before initiating maintenance on the inoperable components.

If the operability of at least one of the two inoperable components is not restored within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the reactor shall be placed in a hot shutdown condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

If the operability of at least one of the two inoperable components is not restored within an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the reactor shall be*

placed in a cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Continued power

. operation with one component out of service shall be specified in Section 3.4.2, with the permissible period in inoperability starting at the time that the first of the two components became inoperable.

Any valves, interlocks and piping directly associated with one of the above components and required to function during accident conditions shall be deemed to be part of that component and shall meet the same requirements as listed for tha_t component.

Any valve, interlock or piping associated with the containment cooling system which is not covered under Specification 3.4.4 above and which is required to function during accident conditions may be inoperable for a period of no more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provided that prior to initiating repairs, all valves and interlocks in the system that provide the duplicate function shall be tested to demonstrate operability.

With service water inlet temperature greater than 53°F, the reactor shall be placed in hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and cold shutdown within an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

3-35 Proposed TSP1186-0163-NL04

3.4 CONTAINMENT COOLING (Cont'd)

Basis An emergency diesel generator is connected to each of the two engineered safeguards 2400-volt buses.

Redundant equipment is connected to each of the two buses to assure that equipment is available under all conditions for minimum containment cooling, and minimum safety injection.

If a piece of equipment is inoperable it is intended it be returned to service promptly after repairs have been completed or action will be taken to place the reactor in a shutdown condition.

The original FSAR analysis of the post-accident containment response determined that a 42" double-ended rupture of the primary coolant piping was the most limiting break with respect to the in-containment response.

It was determined by analysis that three containment air coolers or two containment spray pumps could provide sufficient cooling to limit containment pressure to less than the design condition.

The three air coolers, fed from bus ID and associated with diesel generator 1-2 were therefore considered redundant to the two spray pumps on bus lC associated with diesel generator 1-1.

Additional excess containment cooling was provided with one spray pump on the lD bus included with the three air coolers on that bus and one air cooler fed from bus lC included with the two spray pumps on that bus.

The LOCA analysis did not consider the use of either of-these excess pieces of equipment.

In 1980, as reported in LER 80-003, reanalysis of the Palisades Main Steam ~ine Break Event resulted from a determination that the containment spray initiation time was longer than had been assumed in the FSAR analysis.

Peak containment pressure for a MSLB is mitigated by the actuation of the containment cooling system whereas for a LOCA the peak pressure is initially limited by the heat sinks in containment.

It was determined in the reanalysis that the peak containment pressure during a MSLB is mitigated by the use of the single containment spray pump and the three containment air coolers on the diesel generator 1-2 bus or by the two containment spray pumps on diesel generator 1-1 bus.

Limitations have been imposed on the Service Water System inlet temperature and on the operability of diesel driven fire pumps.

These limitations are required to ensure adequate heat removal occurs for criti~al service water loads when only one diesel generator is operating.

3-36 TSP1186-0163-NL04 Proposed I Proposed 10/20/86 II and 11 /21 /86

4.6 SAFETY INJECTION AND CONTAINMENT SPRAY SYSTEMS TESTS (Cont'd) 4.6.4 4.6.5

b.

Acceptable levels of performance shall be that the pumps start, reach their rated shutoff heads at minimum recirculation flow, and operate for at least fifteen minutes.

Service Water Inlet Temperature With the service water inlet temperature less than or equal to 51°F, the water temperature shall be monitored at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

With the service water inlet temperature greater than 51°F, the water temperature shall be monitored at least once per two hours.

Containment Air Cooling System

a.

Emergency mode automatic valve and fan operation will be checked for operability during each refueling shutdown.

b.

Each fan and valve required to function during accident conditions will be exercised at intervals not to exceed three months.

Basis The safety injection system and the containment spray system are principal plant safety features that are normally inoperative during reactor operation.

Complete systems tests cannot be performed when the reactor is operating because a safety injection signal causes containment isolation and a containment spray system test requires the system to be temporarily disabled.

The method of assuring operability of these systems is therefore to combine systems tests to be performed during annual plant shutdowns, with more frequent component tests, which can be performed during reactor operation.

The annual systems tests demonstrate proper automatic operation of the safety injection and containment spray systems.

A test signal is applied to initiate automatic action and verification made that the components receive the safety injection in the proper sequence.

The test demonstrates the operation of the valves, pump circuit breakers, and automatic circuitry.

(1, 2) 4-40 Proposed TSP1186-0163-NL04

4.6 SAFETY INJECTION AND CONTAINMENT SPRAY SYSTEMS TESTS (Contd)

During reactor operation, the instrumentation which is depended on to initiate safety injection and containment spray is gen~rally checked daily and the initiating circuits are tested ~onthly.

In addition, the active components (pumps and valves) are to be tested every three months to check the operation of the starting circuits and to verify that the pumps are in satisfactory running order.

The test interval of three months is based on t.he judgment that more frequent testing would not significantly increase the reliability (ie, the probability that the component would operate when required), yet more frequent test would result in increased wear over a long period of time.

Verification that the spray piping and nozzles are open will be made initially by a smoke test or other suitably sensitive method, and at least every five years thereafter.

Since the material is all stainless steel, normally in a dry condition, and with no plugging mechanism available, the retest every five years is considered to be more than adequate.

Other systems that are also important to the emergency cooling function are the SI tanks, the component cooling system, the service water system and the.containment air coolers.

The SI tanks are a passive safety feature.

In accordance with the specifications, the water volume and pressure in the SI tanks are checked periodically.

The other systems mentioned operate when the reactor is in operation and by these means are continuously monitored for satisfactory performance.

The service water inlet temperature is monitored periodically to ensure that adequate heat removal capability will be available for critical service water loads.

References (1)

FSAR, Section 6.1.3.

(2)

FSAR, Section 6.2.3.

TSP1186-0163-NL04 4-41 Propo$ed

ATTACHMENT 2 Consumers Power Company Palisades Plant Docket 50-255 RESPONSES TO INFORMATION REQUEST CONCERNING DIESEL FIRE PUMPS December 2, 1986 1 Page ATll86-0l 92-NL02

ATTACHMENT 2 RESPONSES TO INFORMATION REQUEST CONCERNING DIESEL FIRE PUMPS

1.

What is runout on diesel fire pumps?

The diesel fire pumps design flow rate is 1,500 gpm at 125 psig discharge head.

They are also designed to produce a flow rate of 2,250 gpm at 75 psig.

Runout is beyond the latter value.

2.

What is the length of time the diesel fire pumps are needed in the event of a loss of offsite power and failure of the 1-2 diesel generator follow-ing a LOCA?

The diesel fire pumps would be required to operate until offsite power or the 1-2 diesel generator is restored.

If either power source is restored, the two idle service water pumps could be returned to service.

Restora-tion time of a diesel generator or offsite power is not quantified.

However, compliance with the proposed station blackout rule will require all plants to have the ability to restore power within, at the maximum, 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

Therefore, Palisades, in compliance with the rule, will justify the ability to restore power within this time period when considering the offsite power and diesel generator reliabilities.

3.

Was the diesel fire pumps flow tested at 150%?

What is the test frequency?

Technical Specifications surveillance procedure R0-52 is a functional test of the fire water pumps to ensure the design capacity is met and the pumps will deliver 1,500 gpm at 125 psig discharg~ head.

Test data points are taken for five flow conditions to obtain a pump head curve versus flow curve.

The highest flow condition provides a data point at approximately 150% of design flow.

The test condition is restricted by the number of flow test nozzles and not by the pump capacity.

The surveillance frequen-cy is every 18 months but is normally done annually to meet insurance requirements.

4.

Confirm that a fire in the diesel generator 1-2 still allows adequate service water flow for normal cooldown with loss of offsite power.

Consumers Power Company submitted on July 21, 1986, showed that operation of one service water pump or diesel fire pump is all that is required to cool down the plant assuming loss of offsite power and.no LOCA.

There-fore, the reduced flow of the service water pumps does not affect this conclusion.

AT1186-0192-NL02

AT1186-0192-NL02 ATTACHMENT 3 Consumers Power Company Palisades Plant Docket 50-255 SERVICE WATER FLOW DEFICIENCY December 2, 1986 3 Pages

ATTACHMENT 3 SERVICE WATER FLOW DEFICIENCY Discussion of Deficiency 0

LER 86-036, submitted October 30, 1986, described the low flow condition of the service water pump being that the pumps could not deliver the flow at the head values of 8000 gpm at 140 feet of head, as described in the FSAR.

Testing showed the flows to be 6 to 9 percent low.

The cause of the problem is that the now installed replacement impeller had not been backfiled as had the original impellers.

Replacement impellers were installed in. 1980, 1982 and 1983 and the post maintenance testing following replacement was not sufficient to disclose the discrepancy.

The cause of the procurement error is not known, however, the event is considered one input that lead to our conclu-sions concerning programatic weakness in the design basis documentation area.

During the subsequent evaluation of the system it was also found that service water temperatures have exceed the 75°F temperature assumed in the FSAR on several occasions during summer months.

The effect of the low flow on critical service water loads has been determined by testing and analyses and are described below.

The critical loads are the Containment Air Coolers, Component Cooling Water Heat Exchangers, Engineered Safeguards Room Coolers, Control Room HVAC units and the Emergency Diesel Generators.

Testing Initial testing of the Service Water System revealed that except for when all three service water pumps '(designed for 507. capacity each) are available there is insufficient service water capacity to satisfy the post LOCA DBA loads and is an original plant design deficiency.

Although the service water system is described as having two critical headers, there exists no automatic isolation of the headers.

Therefore loads from both headers are supplied by the pumps on either or both safety trains.

A modification and Technical Specification Change Request were initiated to allow blocking flow to the VHX-4 Containment Air Cooler which will allow diverting flow to the remaining required loads.

VHX-4 is not required for DBA conditions.

Subsequent to the decision to block VHX-4, system testing was done to quantify the effect of this proposed modifi-cation.

Testing was done to simulate a DBA condition with loss of off-site power and failure of a safety train (diesel generator).

The testing, with loss of the 1-1 diesel generator (1-2 diesel generator operating) provides two service water pumps to supply cooling to the critical loads.

With flow blocked to VHX-4, design flow was attained to the other three containment air coolers.

However, some of the other critical loads supplied by the two service water pumps did not meet design flows.

These deficiencies of low flow to the control room HVAC units and the engineered safeguards room coolers are not the most limiting flow conditions.

The most limiting flows were attained with only the 1-1 diesel generator and one service water pump operating.

The one service water pump test condition like the two service water pump test condition was done assuming loss of instrument air, which is lost upon loss of off-site power.

Data was also taken assuming instrument air was returned to service.

Operators will return instrument air to service if possible, AT1186-0192-NL02

2 provided such action isn't detrimental to a safe plant cooldown.

The instru-ment air system is not safety grade, but when air is available the limiting conditions with respect to low service water flow are attained.

The reason for this is the air operated temperature control bypass valves on the dis-charge of the Component Cooling Water Heat Exchangers open when air is avail-able.

This results in flow being diverted to the Component Cooling Water Heat Exchangers and from other critical loads.

Data was obtained for the one service water pump test to simulate the pre-recirculation and post-recirculation conditions.

Prior to the recirculation actuation signal (RAS) initiating automatic switchover to the sump, heat loads on the service water system are the lowest when only the 1-1 diesel*generator is operable.

The containment air cooler fans ate not operating.

The contain-ment sprays are taking suction from the Safety Injection and Refueling Water tank and no heat is being removed by the shutdown cooling heat exchanger to the component cooling water system.

In the post RAS con~ition, manual action to align both diesel fire pumps to the Service Water System is assumed.

A minimum of 20 minutes are available to operators for this action, which assumes all engineered safeguards system pumps operating.

Summarizing, four sets of test data for the postulated condition with the only 1-1 diesel generator operating were obtained; both the pre-RAS and post-RAS simulation and with and without instrument air available for both cases.

The results of the testing for these conditions are that each of the*critical components on the 1-1 diesel generator required further evaluation to deter-mine if the flow conditions for the pre-RAS and the post-RAS operation were adequate to ensure operability of components and ensure that plant safety is not compromised for the postulated conditions.

The discussions of the evaluations of the critical components, which result in an additional plant operating constraint for a service water temperature limit of 55°F, follows.

Evaluations For the' engineered safeguards room cooler, the requirement is to maintain the room temperature below 135°F which is the qualification temperature for electrical equipment in the room.

Before recirculation actuation, the heat sources include the pump motors and other electrical loads.

This case was evaluated and it was determined not to be limiting for the minimum service water flow of 74 gpm.

Following RAS the major heat load in the room is the shutdown heat exchanger and piping.

The minimum available service water flow is 110 gpm (assuming operator action to align the fire pumps.)

The required flow is 175 gpm for a service water temperature of 75°F to maintain the room below 135°F.

In order to remove the same amount of heat with 110 gpm service water, the temperature must be below 55°F.

This is presently evaluated as the most limiting condition with respect to plant operation.

For the control room cooling system, the heat load is constant and consists of lighting, equipment and instruments, and people.

Before recirculation actua-tion, the cooling system is assumed to be unavailable due to severe restric-tions in service water flow.

It was calculated that the control room would heat up from 75°F 'to approximately 94°F in the first 30 minutes and would require an additional 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to reach 110°F if cooling was not restored.

The cooling unit is designed for service water flows of 110 gpm at 75°F or 11 AT1186-0192-NL02

3 gpm at 35°F~

The relatinnship is conservatively a~sumed to be linear between these points.

However, service water flow to the cooling unit is measured in differential pressure rather than gallons per minute.

The relationship between service water temperature and differential pressure was developed based on a design point of 97 gpm at a differential pressure head of 28 ft.

The flow is assumed to vary as the square of the pressure differential.

For the limiting post RAS service water differential pressure of 8 psid (assuming operator action to align the fire system), the required service water tempera-ture is approximately 62°F to maintain the control room cooling units in service.

With loss of instrument air, service water flow to one of the CCW heat ex-changers also fell below the required flow of 3300 gpm at 75°F service water temperature.

The actual flow was 3130 gpm.

An analysis with service water flows of 3100 gpm to each CCW heat exchanger indicate that adequate contain-ment cooling is available if the service water temperature is no higher than 69°F.

Two tests and an evaluation were performed to establish the service water temperature operating limit for the diesel generator.

Again, no direct flow indication is available.1 Inlet pressure indication is provided.

In the flow testing described above, the lowest indicated pressure occurred in the pre-RAS testing with no instrument air available.

A pressure of 15 psig was attained.

A second operational test of the diesel generator was performed at full load and the inlet pressure restricted to 10 psig with service water temperature at_

55°F.

The diesel lube oil and jacket water temperatures were recorded for approximately 35 minutes.

The temperatures increased for the first 15 minutes and then stabilized for the remainder of the test.

Lube oil and jacket water operated at 177°F, and 158°F respectively.

Lube oil is the most limiting since it is the closest to its alarm setpoint of 190°F as opposed to the jacket water which has an alarm setpoint of 195°F.

Additionally, it was determined the temperature control bypass valve was bypassing the heat ex-changer to maintain lube oil temperature at 177°F as designed.

The tempera-ture of the fluid passing through the heat exchanger was approximately 20°F less than the control temperature.

Because there was bypass flow, and because the test was run at a service water pressure 50% lower than the service water system test, the resulting evalua-tion has justified operation above the 55°F service water temperature.

conducted.

Simple correlation of the heat-in to heat-out on the lube oil heat exchanger, without assuming any bypass flow, and using the specific heat of the lube oil of.53 BTU/lbm-F and water of 1.0 BTU/lbm-F would justify opera-tion of the diesel generator with 62°F service water prior to reaching the alarm setpoints.

AT1186-0192-NL02

ATll86-0l 92-NL02 ATTACHMENT 4 Consumers Power Company Palisades Plant Docket 50-255 FIRE SYSTEM December 2, 1986 2 Pages

ATTACHMENT 4 FIRE SYSTEM The Palisades fire water system is designed in accordance with the require-ments of the National Fire Protection Association and American Water Works Association. standards and applicable codes and regulations of the State of Michigan.

The fire pumps are located in the intake structure, which also houses the service water pumps.

The intake structure is a seismic category I building and meets the Consumers Power Company design classification of a Class 1 structure (FSAR section 5.2.2).

The fire system diesel driven fire water pumps and piping connected to the auxiliary feedwater pump section and critical service water header are Consumers Power Company Class 2, which are non-safety class, but are designed to functionally withstand a one-half Operational Basis Earthquake.

The Fire Protection System meets the requirements of Criterion 3 to 10CFR50 Appendix A.

The fire water supply conforms to the provisions of Appendix A to Branch Technical Position 9.5-1.

The diesel driven fire pumps (and electric pump) have a rated capacity of 1,500 gpm at 125 psig discharge pressure.

The fire pumps can be operated automatically, based on fire water system pressure and can also be started manually from the control room or locally at the pumps.

The diesel fire pumps fuel supply is gravity fed from their respective day tanks.

The day tanks are filled automatically, following a low level actua-tion, by either of two fuel oil transfer pumps taking suction from the diesel oil storage tank.

Provisions for emergency filling the day tanks via a hand pump are available.

This operation is described in the system operating procedures.

Technical Specification Surveillance requirements for system operability, in Section 4.17.2, require monthly operating tests and functional testing every 18 months.

The 18 month test is usually conducted annually to meet insurance requirements.

The cross-connections from the fire pump discharge headers are provided with hand operated valves to the two critical service waterlines.

A cross-connection is also provided that connects the fire system to the suction of the auxiliary feedwater pumps P8A and P8B.

Alignment of the Fire Water System to the Service Water System during accident conditions was evaluated during the Systematic Evaluation Program.

SEP Topic IX-3, Station Service and Cooling Water Systems, evaluation dated February 22, 1982, by the NRC staff, conclud~d that, if a LOCA were to occur concurrent with a loss of offsite power and a single failure of diesel generator 1-2, sufficient service water might not be available to prevent exceeding the thermal design limit of the component cooling water (CCW) system.

A subse-quent evaluation by Consumers Power Company.determined that other critical components would not receive adequate flow as loss of air to the CCW heat exchanger valves would allow the valves to go to full open increasing flow to the heat exchanger but decreasing other component flows.

Valve stops were installed on the CCW heat exchanger valves to limit service water flow and procedures were revised to require alignment of the Fire Water System to the Service Water System if only one service water pump were available.

The NRC AT1186-0192-NL02

staff Safety Evaluation of May 31, 1983 concluded the proposed~action was acceptable.

2 Alignment of the Fire Water System to the Service Water System is a manual action that will not be required coincident with demand on the fire system for fire suppression.

Augmenting the service w~ter system following a postulated LOCA, loss of offsite power, and failure of the 1-2 diesel generator has been determined to be necessary after recirculation from the containment sump has begun.

The minimum time to recirculation is 20 minutes and assumes all engineered safeguards pumps operating.

The postulated failure of the 1-2 diesel generator would eliminate one train of pumps and extend the time beyond 20 minutes before the recirculation actuation signal (RAS) is initiated.

Alignment of the Fire Water System to the Service. Water System will be re-quired within the time period prior to the RAS initiation.

AT1186-0192-NL02

ATTACHMENT 5 Consumers Power Company Palisades Plant Docket 50-255 NOVEMBER 24, 1980 TECHNICAL SPECIFICATIONS CHANGE REQUEST CONTAINMENT SPRAY INITIATION TIME December 2, 1986 4 Pages AT1186-0192-NL02

consumers

• Power company 9ao1124a General Offices: 212 West Michigan Avenue, Jackson, Michigan 49201

• Area Code 517 788-0550 November 24, 1980 Director, Nuclear Reactor Regulation Att Mr Dennis M Crutchfield, Chief Operating Reactors Branch No. 5 US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT PROPOSED TECHNICAL SPECIFICATIONS CHANGE RELATED TO CONTAINMENT SPRAY INITIATION TIME

("""

'2' 0*~;

Attached are three (3) original and thirty-seven (37) copies of a request for-change to the Palisades Plant Technical Specifications.

Licensee Event Report CLER)80-003, dated April 3,1980, reported that initiation times of the containment sprays and full load steam flow for the main steam line break analysis were in error.

As a result of a reevaluation of this problem, it was noted that Technical Specifications changes may be needed.

Our LER update submitted on May 13, 1980 described the potential Technical Specifications changes and is the basis for this request.

The requested changes involve a single issue; therefore, a check in the amount of $4,000 is attached pursuant to 10 CFR 170.22, Class III change.

David P Hoffman (Signed)

David P Hoffman Nuclear Licensing Administrator CC Director, Region III, USNRC NRC Resident Inspector-Palisades

!,.n CONSUMERS POWER COMPANY Docket 50-255 Request for Change to the Technical Specifications License DPR-20 1

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 3.4.1 to read as follows:

"3. 4.1 The primary. coolant system shall not be heated above 325°F unless the following conditions are met:"

B.

Add the following to Section 3.4.1:

"3.4.1.d Both containment spray head.ers are filled to a level greater than the 735-foot elevation."

C.

Delete* the following from the Basis of Section 3.4.1:

"The containment spray system is redundant with the containment air circulation and cooling system.

(1) It is sized such that two of the three pumps will limit containment prP.ssure to less than design pressure following a OBA without taking credit for the safety injection tanks.

(2) Three of the four air coolers have the capability of limiting the containment pressure under the same conditions as the two pumps."

-0 N

D.

Add the following paragraph to the Basis of Section 3.4.1:

E.

"AnMSLB or LOCA produces a rapid pressurization of containment immediately following the break.

Operation with the spray header filled to the 735-foot elevation minimizes the time prior to establishment of fully developed spray flow.

Inoperability of one of the headers is permitted for a 7-day period since the other header remains operable, artd heat removal capability is still provided by the containment air coolers.

Spray flow is established in.the zero power case, with both spray headers drained, early enough to prevent containment pressure from exceeding the design limit."

Revise Section 3.6.2 to read as follows:

113.6.2 The internal pressure shall not exceed 1.0 psig (except for containment leak rate tests)."

nu0880-0446a-43

-o

"-r N

'° C'\\I 2

F.

Revise Item 1 of Table 3.16.1 to read as follows:

Functional Unit

1.

High Containment Pressure Channel Setting Limit *

a.

Safety Injection 5 - 5.75 Psig

b.

Containment Spray

c.

Containment Isolation

d.

Containment Air Cooler OBA Mode

e.

Steam Line Isolation G.

Revise Item 4 of Table 3.16.1 to read as follows:

Functional Unit Low Steam Generator Pressure Channel Steam Line Isolation Feed Line Isolation Setting Limit

~ 500 Psia(3)

H.

Add Item 15 to Table 4.1.3:

15.

Containment Spray Header Level

a.

Check

b.

Calibrate w

R

a.

Normal Readings Observed

b.

Known Pressure Applied to Sensor II.

Discussion A.

B.

This change will require the equipment identified in Sections 3.4.1.a, band c to be available prior to criticality. This will add a margin of safety to the Plant since this safety equipment will be available in the event of a zero power steam line break.

This proposed Technical Specifications change results from actions identified in the follow-up to LER 80-003 (Containment Spray).

By filling both containment spray (CTS) headers to a level greater than the 735-foot elevation, the actuation time of CTS system, during an MSLB or LOCA, is reduced.

A faster response by the CTS system results in a lower containment pressure during an MSLB or LOCA.

C.

This paragraph in the Basis Section 3.4.1 can be deleted.

It is no longer applicable to the Palisades Plant.

D.

The proposed paragraph to the Basis Section 3.4.1 is self-explanato_ry.

E.

The proposed change for Section 3.6.2 changes the internal containment pressure limit, during operation, from 3 psig to 1 psig.

Analysis shows if the initial containment pressure is greater than 1 psig that, in the event of a LOCA or MSLB, the containment pressure design will be exceeded.

From an operational standpoint, ~ 1 psig

• is achievable.

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III.

F.

The addition of steam line isolation to Table 3.16.1, Item 1, is a result of the analysis performed in conjunction with LER 80-003.

3 The purpose of this change is to reduce the mass and energy. added to containment in the event of a main steam line break incident:

G.

The addition of the feedwater line to Table 3.16.1, Item 4, is a result of a modification made in conjunction with LER 80-003.

The purpose of this modification is to provide feedwater isolation when steam generator pressure falls below 500 psia.

H.

These changes are needed to provide continuity with the proposed Technical Specifications changes (Item B above) that have resulted from LER 80-003 (Containment Spray initiation times).

Conclusion Based on the foregoing, both the Palisades Plant Review Committee and the Safety and Audit Review Board have reviewed these changes and find them acceptable.

('\\l CONSUMERS POWER COMP ANY By R B DeWitt (Signed)

R B DeWitt, Vice President Nuclear Operations Sworn and subscribed to before me this 24th day of November 1980.

C\\l Linda K Carstens (Signed)

Linda K Carstens, Notary Public Jackson County, Michigan My commission expires June 10, 1981.

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