ML18053A587

Application for Amend to License DPR-20,incorporating Containment Isolation Valve Spec to Allow for Manual Operation of Penetration 33 Isolation Valves at Power for Sampling Safety Injection Tanks Into Tech Specs

ML18053A587
Person / Time
Site:	Palisades
Issue date:	09/15/1988
From:	Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML18053A570	List: ML18053A568 ML18053A572 ML18053A587
References
NUDOCS 8809280003
Download: ML18053A587 (6)

Text

L' 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. Section 1.4 Definitions - Containment Integrity

a. All nonautomatic containment isolation valves and blind flanges are closed (operable) except as noted in Table 3.6.1.

b. All automatic containment isolation valves are operable (as demonstrated by satisfying isolation times specified in Table 3.6.1 and leakage criterion in Specification 4.5.2) or are locked closed.

B. Section 3.6.1 Containment Integrity Change to read:

_a. Containment integrity as defined in Specification 1.4 shall not be violated unless the reactor is in the cold shutdown condition.

b. Containment integrity shall not be violated when the reactor vessel head is removed unless the boron concentration is greater than refueling concentration.

c. Except for testing one rod at a time, positive reactivity changes shall not be made by control rod motion or boron dilution to less than cold shutdown boron concentration unless the containment integrity is intact.

ACTION:

With one or more containment isolation valve(s) inoperable

- (including during- performance of valve testing), - maintain at least one isolation valve operable in each affected penetration that is open and either:

a. Restore the inoperable valve(s) to operable status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or

b. Isolate each affected penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least one deactivated automatic valve secured in the isolation position, or

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Isolate the affected penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at 2

least one closed manual valve or blind flange; or

d. Be* in at least hot shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

BASIS The operability of the containment isolation valves ensures that the containment atmosphere will be isolated from the outside environment in the event of a release of radioactive material to the containment atmosphere or pressurization of the containment.

Containment isolation ensures that the release of radioactive material to the environment will be consistent with the assumptions used in Section 14 events of the Palisades FSAR.

The above limiting conditions of operation provide time in which troubleshooting, repairs and pressure testing of isolation valves may occur.

Add: New Table 3.6.1 Containment Penetrations and Valves as shown in the page changes.

C. Section 3.6.5 Containment Purge and Ventilation System Change the basis to read:

BASIS The containment purge and ventilation isolation valves are required to be closed in conditions above COLD SHUTDOWN, until it can be demonstrated that the valves meet the requirements of Standard Review Plan 6.2.4 and Branch Technical Position CSB 6-4. To ensure that the valves are closed and that the seals.

have not degraded, a between the valves leak rate test will be performed. Maintaining these valves closed during plant operations ensures that excessive quantities of radioactive materials will not be released via the containment purge or ventilation systems as detailed in a & b above.

The current method of maintaining Containment Building pressure below one psig is by the removal of non-condensible gases from the Containment Building through a clean waste receiver tank whose rupture disc has been removed and then ultimately to the Plant stack. This path is isolated by two automatic isolation valves prior to entry into the Plant stack.

D. Section 4.5.6 Containment Isolation Valves Add this new section to read:

a. The isolation valves shall be demonstrated operable by performance of a cycling test and verification of isolation OC0588-0022C-NL02-LI01-NL04

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• time for auto isolation valves prior to returning the valve 3

to service after maintenance, repair o~ replacement work is performed on the valve or its associated actuator, control or power circuit.

b. Each isolation valve shall be demonstrated operable by verifying that on each containment isolation right channel or left channel test signal, applicable isolation valves actuate to their required position during cold shutdown or at least once per refueling cycle.

c. The isolation time of each power operated or automatic valve shall be determined to be within its limit as specified in Table 3.6.1 when tested in accordance with Section XI of the ASME Boiler and Pressure Vessel Code.

E. Table of Contents Add: Table 3.6.1 Containment Penetrations and Valves Add:

Section 4.5.6 Containment Isolation Valves II. Discussion The above proposed Technical Specification Changes are requested to provide consistency with Standard Technical Specifications (STS) with respect to requirements for containment isolation valves.

A. The definition for containment integrity was changed to specifically identify the exception that allows for the opening of certain manual containment isolation valves at power.

B. The first change to Specification 3.6.1 is an administrative change to the reference to the definition Section 1.4.

Specification 3.6.1 was changed to incorporate the requirements on containment isolation valves consistent with the STS *. The Limiting Condition for Operation specifically proposes exemp-tions for opening of the safety injection tank drain manual isolation valves which is consistent with the asterisk footnote on STS Table 3.6-1. The Action Statement from the STS has been modified to clarify that the Specification also applies during performance of valve testing.

This change to Specification 3.6.1 does not directly affect Section 3~6.3. Section*3.6.3 basis requires verification that all locked closed valves are locked closed prior to startup.

However, since manual isolation valves were not considered to be opened at power before the changes to 3.6.1 and the addition of Table 3.6.1, further verification of valve closure is believed to be necessary. The verification of valve clos~re is currently

• addressed in Plant Administrative Procedure 4.02.

The addition of Table 3.6.1 Containment Penetrations and Valves corresponds to the Table 3.6-1 in STS.

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The changes to Specification 3.6.5 basis was added to describe.

4 the present containment vent path to maintain Containment Building pressure below one psig and avoid any confusion regarding this vent path.

D. The Surveillance requirements of the STS were modified as applicable for Palisades.

E. The Table of Contents was changed to administratively account for the other proposed changes.

Analysis of No Significant Hazards Consideration The changes noted in this request are being proposed in order to allow opening of certain manually operated containment isolation valves in operational conditions other than Cold Shutdown and Refueling and to include Action Statements which address isolation valve inoperability.

This proposal includes the allowance to open the manual isolation valves associated with the safety injection tank drain line. Each of the four safety injection tanks (T-82A-D) has a one inch diameter drain line penetrating the lower region of its shell. Each of these lines feed into a common two inch header which passes through the Containment Building penetration 33. Beyond the penetration two locked-closed manual isolation valves provided in series, maintain containment integrity. Following these isolation valves flow can be routed to the safety injection refueling water tank, equipment drain tank or a sample tap located at the Nuclear Steam Sampling System Panel. Palisades Technical Specifications (TS) Table 4.2.1.5,

Minimum Frequencies for Sampling Tests" requires the monthly sampling of the safety injection tanks for boron concentration. The basis for this Specification declares that the prescribed sampling is required to assure safety injection tank boron concentration is maintained. The infrequent sampling period reflects a static system not normally subject to change.

Current TS does not specifically allow the opening of manual isolation valves unless the reactor is in the cold shutdown or refueling conditions. This proposed change, therefore, presents an Unresolved Safety Question (URSQ) due to a reduction in the margin of safety inherent to the basis for TS 3.6. However, no sig~ificant hazard is presented to the general public by this change fn that no new accident or malfunction is created by opening of the isolation valves and that the consequences of an accident or malfunction of equipment important to safety is not fncr'eased *.

Standard Review Plan 15.6.5 Appendices A and B require the calculation of doses attributable to a release of airborne fission products from the containment atmosphere to the environment. These doses include the contributions from allowed containment leakage, containment purge and ventilation systems and post-loss of coolant accident (LOCA) leakage from engineered safety feature (ESF) systems OC0588-0022C-NL02-LI01-NL04

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• outside containment. The Palisades Final Safety Analysis Report 5

(FSAR) currently includes the off site dose contribution for allowable containment leakage, 0.1 percent per day, and the post-LOCA leakage from ESF systems outside containment. Table 14.22-3 shows the limiting dose to be 100.1 Rem to the thyroid and 1.07 Rem to the total body at the exclusion area boundary. The dose contribution from the containment ventilation system as described in TS 3.6.5 is not currently included in the FSAR, however", it was ca;J.culated to be 164.3 Rem thyroid and 8.83 Rem total body as reported in Licensee Event Report (LER) 50-255/88-010. Since submitting the LER, the containment ventilation system dose calculations have been refined such that the additional exclusion area thyroid and total body doses are now 102.5 Rem and 5.49 Rem respectively. Therefore, the limiting thyroid and total body doses from all Standard Review Plan leakage pathways are calculated to be 202.6 Rem and 6.56 Rem respectively.

These values are well below the 10CFRl00.11 limiting doses of 300 Rem thyroid and 25 Rem total body.

Palisades FSAR boundary off site dose calculations are based on Standard Review Plan assumptions and maximum hypothetical accident initial conditions. These conditions include the existence of maximum containment design pressure and a Regulatory Guide 1.4 source term at the onset of the event. Further it is assumed the isolation valves associated with the containment ventilation system do not close for the full 25 second limiting stroke time. No lines which penetrate the Containment Building are assumed to fail, therefore, no additional direct connections between the containment atmosphere and the environment beyond the ventilation system exist. It should be

. noted that the containment sump drain line communicates directly with containment atmosphere, however the Standard Review Plan does not require this contribution to be considered.

In order for opening of the containment isolation valves associated with safety injection tank sampling to present a significant hazard to the general public, the assumptions presented in Standard Review Plan 15.6.5 and its Appendices would have to be exceeded. For a release of radioactive material to occur due to this proposed TS change, the following would have to occur concurrently:

1. A core damaging accident which causes fission products to be released to the containment atmosphere.

2. Mechanism for pathway from containment atmosphere to environment

a. A safety injection tank drain line failure such that a pathway would exist from the containment atmosphere or,

b. A failure *of two check valves between the reactor coolant and safety injection tank discharge piping.

3. The required TS sampling for boron concentration in progress.

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• While a quantitive probability has not been defined for these events 6

occurring concurrenlty, the total probability is believed to be extremely small. In addition to assure timely manual valves closure while sampling, Plant operators will be required to remain in appropriate protective clothing in the vicinity of the valves.

Based on the results of the dose consequence analysis being within limits specified in 10CFRlOO .11, the acceptably small probability of the concurrent events and administrative controls, this change complies with the staff's position as presented in the Standard TS of allowing the opening of certain manual containment isolation valves while at power operation and does not present a significant hazard.

Other proposed changes included within this submittal include the addition of Action Statements for containment isolation valve inoperability and applicable surveillance requirements. Changes noted in this submittal reflect the as-built and operational configuration of the Palisades Plant, and are believed to reflect the staff position as presented in Standard TS and NUREG-0737, "Clarification of TMI Action Plant Requirements". Based on the no significant hazards considerations presented above and the staff position presented in Standard Technical Specifications, we believe this mode of operation is acceptable. The changes reflected within this Technical Specification Change Request regarding penetration 33 supers~des previous correspondence in regards to NUREG 0737 item II.E.4.2.

III. Conclusion The Palisades Plant Review Committee has reviewed this Technical Speci-fication Change Request and has determined that this change does involve an unreviewed safety question but an analysis of no significant hazards considerations has been performed and the change has been found to involve no significant hazards considerations. This change has also been reviewed under the cognizance of the Nuclear Safety Board. A copy of this Technical Specification Change Request has been sent to the State of Michigan official designated to receive such Amendments to the Operating License.

CONSUMERS POWER COMPANY By~David P Hoffman, Nuclear Operations Sworn and subscribed to before me this 15th day of September 1988.

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Elaine Euehrer, Notary Public Jackson County, Michigan My commission expires October 31, 1989 OC0588-0022C-NL02-LI01-NL04