ML20002C755
| ML20002C755 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 06/15/1973 |
| From: | Lamley R, Sewell R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Oleary J US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| NUDOCS 8101100821 | |
| Download: ML20002C755 (7) | |
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June 15, 1973
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Mr. John F. O' Leary, Director Re: Docket No 50-155 Directorate of Licensing License No DPR-6 US Atomic Energy Comission Proposed Technical Washington, DC 20545 Specification Change N' 38
Dear Mr. O' Leary:
Transmitted herewith are three (3) executed and thirty-seven (37) conformed copies of a Request for Change to the Technical Speci-fications of License DPR-6, Docket No 50-155, issued to Consumers Power Company on May 1,1964 for the Big Rock Point Plant.
This proposed change (No 38) modifies testing requirements associated with three valves and also incorporates several procedural changes as suggested by the AEC staff.
Yours very truly,
@dM uu RBS/ map Ralph B. Sewell Nuclear Licensing Administrator CC: BHGrier, USAEC
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CONSUMERS POWER COVJANY Docket No 50-155 Request for Change to the Technical Specifications Change No 38 License No DPR 6 For the reasons hereinafter set forth, the following changes to the Technical Specifications of License No DPR-6 issued to Consumers Power Company on May 1,1964, for the Big Rock Point Plant are requested:
I.
Changes A.
Section 3 Change Section 3 7(b) to read as follows:
"(b) At least once every twelve months, the following valves shall be tested for operability from both the manual and automatic modes of operation and, at the same time, shall be tested for leak tightness by means of a pressure test utilizing air or the normal working fluid at a pressure not less than 20 psig:
Main Steam Isolation (MO-7050)
- Main Steam Drain (MO-7065)
Clean-Up System Resin Sluice (CV-4091)
Reactor and Fuel Pit Drain Isolation (CV 4027 - CV-4117)
Reactor Enclosure Clean Sump Isolation (CV-4031 - CV-4103)
Reactor Enclosure Dirty Sump Isolation (CV 4035 - CV 4103)
All significant leaks revealed by these tests shall require repair of valve seals and retests.
Automatic controls and instrumentation associated with these valves shall be tested e', approximately quarterly intervals; these tests may be conducted with a simulated signal or in such other manner a.s to obviate plant shutdown.
- Operability, automatic controls and instrumentation tests required only if valve is opened for use during operation."
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B.
Section 4 Change summary titled " Recirculating Valves, Each Loop" listed in Section 4.1.2(a) to read as follows:
Size - Opening Rate Location Type Mode of Operation Inches Inches / Min Pump Suction Gate Motor 24 12 Pump Discharge Gate Motor 20 5
Pump Discharge Gate Motor 5
12 Bypass Valve Pump Discharge Butterfly Electrically Disabled and Locked in the Full Open Position" C.
Section 6 Change Item 6.1.2 concerning recirculation line valve closure sensor and trip devices in the " Scram Setting and Tolerance" column to read as follows:
"Approximately 10 percent of full simitaneous closure of both discharge or both suction valves or any combination of both of these valves, one in each loop."
D.
Section 7 1.
Change Section 7.1.2 to read as follows:
"7.1.2 There shall be at least two operations personnel (one of whom shall be an AEC licensed operator) in the con-trol room for start-up and shutdown of the plant. A second AEC licensed operator shall observe all control rod movements associated with critical approaches on start-up to ensure these control rod movements are perfomed in accordance with established control rod withdrawal procedures. There shall be at least one AEC licensed operator in the control room at other times during power operation and also during refueling.
No licensed operator shall be required in the control rocxn when reactor is in the cold shutdown condition as defined in Section 1.2.6.
The minimum shift comple-ment shall consist of a Shift Supervisor and two operations personnel."
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3 2.
Chan6e Paragraph (a) of Section 7 2.1 to read as follows:
"(a) Written procedures for normal and emergency operations which may involve nuclear safety shall be prepared and issued prior to the initial start-up of the plant.
The above procedures shall be reviewed and approved by responsible persons on the Plant Operating Staff and by appropriate representatives of the Company's General Office in Jackson. These procedures shall conform. to the Technical Specifications. Copies of the Site Emer-gency Plan will be kept in the Control Room, Auxiliary Equipment Room, Information Center and the Company's General Office."
II.
Discussion A.
Butterfly Valves There is one reactor recirculating pu=p discharge butterfly valve located in each of the two primary system loops. In addition, there are also reactor recirculating pu=p isolation valves in each loop and on each side of the pu=ps.
These isolation valves are gate-type valves. The but-terfly valves were used to throttle flow such that thermal hydraulic data associated with different rates could be obtained during the Research and Development Program conducted during the initial operation of the Big Rock Point Plant. The butterfly valves were intended to serve no other purpose than to aid the Research and Development Program.
(This is confirmed by Section 5.4.2.4 of the FHSR which states that these valves were installed to regulate pu=p discharge during the Research and Development Program but, if valve operation is no longer required, they may be made inoperative in the open position.) The valves have not been used since June 1964 and have been mechanically and electrically disabled in the open position.
Original plant design provided reactor trip devices such that if at approximately 10% of full simultaneous closure of both discharge or both suction valves, or simultaneous closure of the butterfly valves to the po-sitions comparable to a 55% decrease in flow from full flow, or any closure combination of two of these valves, one in each loop, a reactor trip would occur. As the butter" valves are disabled in the full open position, it is desirable to eliminate the trip testing requirements as delineated in
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h the Technical Specifications. These valves are located in a high radia-tion area and the needless trip testing requirements dictate unnecessary radiation exposure to plant personnel.
The valve operating motor has been disabled by electrically dis-connecting the motor. Manual operation of the valve is prohibited by a chain and lock arrangement on the handwheel. Inadvertent valve closure due to mechanical failure of the valve has also been analyzed. The valve design is such that there is no net closing force exerted by the coolant on the valve disc. Therefore, it was concluded that it was highly unlikely that a mechanical failure would either allow or cause the valve to close.
Even so, assuming the operating shaft were to break, or a key were to shear, or the closure of the valve could in scue way occur, plant response would be no different than if the trip still existed. As the trip circuitry sen.:es from the valve operator motor, a failure of the type described above would not be seen by the valve position indication. In either case, indications would be immediately available in the control room that flow had been re-duced in a recirculating loop. In addition, even if the trip circuitry could have sensed this closure, the plant would not shut down automatically because the trip circuitry requires simultaneous flow blockage in both re-circulating loops. In the event that recirculating flow is decreased (through inadvertent closure of a valve), the reactor power is reduced accordingly. In fact, in Procedure B29.4.1 of the Procedures Manual, it is stated that if power is to be reduced quickly it can be done by tripping a reactor recirculating water pu=p.
B.
Main Steam Drain Valve The main steam draiu valve (MO-7065) is no longer used and is left in the closed position. It is no longer used because of repeated difficu2 ties with the d-c motor operator and it was determined that no operating difficulties would exist if the valve were left closed permanently.
As this valve is classified as a containment isolation valve, necessary actuation circuitry is provided to shut this valve automatically if it is in the open position. Since this valve is left in the closed po-sition, there is no need to test the valve for operability once every twelve (12) months. provisions have been made in this proposed change to provide
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testing in the unforeseen circumstance that it becomes necessary to use this valve in the future.
C.
Operating Procedures The change to Section 71.2 is proposed as requested by a member
- of the staff of the Directorate of Licensing to ensure that two qualified personnel are monitoring control rod motion during critical approaches.
This change will reduce the probability of out-of-sequence control rod motion from occurring.
Consumers Power Ccapany has always interpreted the requirements l
of Section 7 2.1(a) of the' Technical Specifications as requiring General Office review and approval of plant procedures important to nuclear safety prior to initial plant start-up. Directorate of Regulatory Operations per-sonnel pointed out that this section can also be interpreted as to require This review of operating procedures revisions prior to any plant start-up.
proposed change inserts the word " initial" prior to " start-up" to clarify the interpretation of this section.
CONSUMERS POWER COMPAfE,
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ByR. A. Lamley, Vice Presfdent Date: June 15, 1973 Sworn and subscribed to before me this 15th day of June ICJ73
$~ts b. bn h Notary Publi/:, Jackson County, Michigan My commission expires May 18, 1976 i
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