ML18054A891

Application for Amend to License DPR-20,revising Tech Specs to Delete Critical Svc Water Header Hydrostatic Test Requirements.Svc Water Sys Would Be Tested Per Less Restrictive ASME Code Requirements for Class 3 Subsystems

ML18054A891
Person / Time
Site:	Palisades
Issue date:	08/02/1989
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18054A892	List: ML18054A891 ML18054A893
References
TAC-73598, NUDOCS 8908100217
Download: ML18054A891 (4)

Text

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consumers

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Power Kenneth W Berry Director

- -. PllWElllllli Nuclear licensing llllUllliAll'S PIUllillESS General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-1636 August 2, 1989 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

TECHNICAL SPECIFICATION CHANGE REQUEST - !SI-TESTING (TAC NO. 73598)

Enclosed is a request for change to the-Palisades Technical Specifications.

This change request revises the Technical Specifications to delete critical service water header hydrostati~ test requirements. In place of the existing Technical Specifications requirement, the service water system would be tested in accordance with the ASME Code requirements for Class 3 systems, which are less restrictive. Consumers Power Company requests this change be approved prior to the next Palisades refueling outage so the higher pressure hydrostatic test will not have to be conducted. The next refueling outage is currently planned for the fall of 1990.

Kenneth W Berry Director, Nuclear Licensing CC Adminis~rator, Region III, USNRC NRC Resident Inspector - Palisades .~- ,.

Attachments OC0789-0150-NL04 8908100217 8'°i'(>:=:(>2 PDR ADOCK 05000255 p PDC

• 1 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 Change Technical Specification Table 4.2.2, Item 10 to read:

"10. Deleted" II. Discussion This proposed Technical Specification change is requested to provide consistency with the ASME Boiler and Pressure Vessel Code,Section XI testing requirements. The Palisades service water system piping design pressure is 100 psig with a normal operating pressure of 65 psig. It is an ASME ~ode Class 3 system. The current Technical Specification Table 4.2.2, Item 10, requires the service water system to be hydrostatic tested to 150 psig (1.5 times system design pressure) every 5 years, in addition to the ASME Code inservice testing requirements. Under the ASME Code,Section XI, an inservice test consisting of a VT-2 walkdown inspection at normal operating pressure is required once each inspection period of 3-1/3 years with one of the tests conducted at 125 psig (1.25 times.system design pressure) each inservice inspection interval of 10 years~ To comply with the additional Technical Specification requirement, *two. of the 3-1/3 year- inspection period tests have been conducted at 150 psig.

Through design document reviews and correspondence searches, a basis for selection of the 150 psig test pressure every 5 years is not able to be.

determined. The existing .Technical Specification was implemented prior to the evolution of the current ASME Code,Section XI inservice testing requirements for Class 3 syste~s and appear to have been chosen on the basis of engineering judgement. The critical headers of the service water system are part of a Class 3 system and should be tested in accordance with the ASME Code.

OC0789-0150-NL04

• 2 Testing the critical headers of the service water system to 150 psig is not necessary to determine system operability. Since initial plant operation no system piping deficiencies have been detected during the 150 psig testing. Hydrostatic testing in accordance with the ASME Code would be consistent with industry practice for Class 3 systems and Standard Technical Specifications. Therefore, it is proposed the requirements of Technical Specification Table 4.2.2, Item 10 be deleted.

Hydrostatic testing for the critical headers of the service water system would be conducted in accordance with the ASME Code,Section XI.

III. Analysis of No-Significant-Hazards-Consideration This proposed change to the Technical Specifications does not involve any physical changes to the plant nor does it eliminate any testing requirements. This change reduces the hydrostatic test pressure requirement for the critical service water headers from 150 psig (1.5 times system design pressure) to 125 psig (1.25 times system design pressure) and changes the frequency from once every 5 years to once every inservice inspection interval of 10 years. The normal operating pressure of the service water system is 65 psig with a maximum pump shut off pressure of 104 psi and there are no operating or design considerations which would require a higher test pressure with a greater testing frequency.

This proposed change will lengthen the time between tests and reduce the hydrostatic test pressure, therefore, there is no change to the consequences of an accident previously evaluated and the possibility of a new or different kind of accident is not created. The probability of an accident or malfunction is not increased since there is no physical change to the service water system piping, the duty cycle on the piping is not changed, and the proposed testing requirements are in accordance with the governing ASME Code. The margin of safety is not reduced because testing at 150 psig once every 5 years is in accordance with the ASME Gode,Section XI.

IV. Conclusion The Palisades Plant Review Connnittee has reviewed this Technical Specification Change Request and has determined this change does not involve an unreviewed safety question and, therefore, involves no significant hazards consideration. This change has been reviewed by the OC0789-0150-NL04

• 3 Nuclear Safety Services Board. A copy of this Technical Specification Chagg~Reques~ has been sent to the State of Michigan official designated to receive such Amendments to the Operating License.

CONSUMERS POWER COMPANY To the best of my knowledge, information and belief, the content$ of this Technical Specification Change Request are truthful and complete.

By ce President tions Sworn and subscribed to before me this 2nd day of August 1989.

Beverly nn Avery, Not y Public Jackson County, Michigan My commission expires December 7, 1992 OC0789-0150-NL04