ML20002C836
| ML20002C836 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 08/12/1977 |
| From: | Bilby C, Skibitsky W CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Desiree Davis Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20002C837 | List: |
| References | |
| NUDOCS 8101120139 | |
| Download: ML20002C836 (9) | |
Text
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i Consumers t POVlCr
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Company Gene-al Othces: 212 West Michigan Avenue. Jackson Michigan 49201 Area Code S17 788-0550 August 12, 1977
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Director of Nuclear Reactor Regulation A t/
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Att: St Don K Davis, Acting Branch Chief
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Operating Reactor Eranch Iio 2 US Nuclear Regulatory Co==ission
'4ashington, DC 20555 DOCKET 5C-155 - LICE!ISE DPR BIG RCCE POII;T PLAI;T - ECCS T/S CHAIiGE REC.UEST Transmitted herewith are three (3) original and thirty-seven (37) ccnformed copies of a proposed change to the Technical Specifications for the Big Rock Point Plant, Docket 50-155, License DPR-6.
The purpose of this change is to reflect changes cade to the Big Rock Point Energency Core Cooling System (ECCS) as required by the Cc==ission's I*emoran-dum and Order dated May 26, 1976. In general, these changes reflect the quali-fication of the ECCS backup core spray nozzel and the on-line testability of the ECCS and encompass changes to surveillance requirements, Limiting; Cenditions for Operation and the Bases sections as derived from thee? events.
Because plant start-up from a refueling outage is scheduled for the first week of September 1977, approval of this proposal is requested by September 1,1977
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Alg W S Skibitsky
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Nuclear Licensing Engineer CC: JGKeppler, US:iRC l'
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k CONSUMERS POWER COMPANY Dochet 50-155 4
Request for Change to the Technical Specifications License DPR-6 i
For the reasons hereinafter set forth, _ it is requested that the Technical Specifications contained in Provisional Operating License DPR-6, Docket 50-155, be changed as described in Section I, below:
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Changes
'A. ~ Section ll.h.1.h'.A.
1.
Delete:
(a) " Verify the Operability of M0-7051, -7061, -7066, -7033 and
-7074 by remote manual actuation."
-(b) " Verify that the check valve between MO-7051 and -7061 is not i
stuck shut."
2.
Add:
(a) "7erify the following valve locked or sealed in the open position:
MO-7069."
(b) " Verify the-following valve locked or sealed in the shut position:
Upstream manual isolation valve for transformer deluge valve."
B.
Delete Section 11.h.l.h.B.
-4 C.
Section 11.k.1.k
- C.
1.
Replace:
(a)
"#C.
At least once every six (6) months, except for periods of continuous shutdown, when the following shall be performed prior to start-up" with "B.
At each major refueling outage,
'the following shall be performed:"
2.
Add:
4 (a) " Manual and" before " auto =atic."
(b)
" Manual actuation of valve MO-7066."
-(c) " Perform pressure test.of backup cooling supply hose for post-
-incident heat exchanger."
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Section 11.h.l.k.D:
1.
Delete:
(a)
"D.
At each major refueling outage, the following shall be performed:"
(b) " Actuation and."
E.
Section 11.h.1.h*E-3.
Change:
-(a)
"#E" to "C."
(b) " Table 11.h.1.h(a)" to " Table 11.h.1.ha."
F.
Delete Section 11.'3.1.h.F.
G.
Section 11 3.1.h.G.
1.
Change:
(a)
"G" to "F."
(b) " Table 11.3.1.h(a)" to " Table 11.3.1.ha."
H.
Delete the asterisked (*) footnote at bottom of Paragraph ll.h.1.h.
I.
Tables,EL.3.1.ha and ll.h.l.ka.
j 1.
Change " cores" to " core."
2.
Under column entitled " Parameter":
(a) Change footnote reference "(b)" to "(a)."
(b) Change " Steam Drum" to " Primary."
3 Under column entitled " Conditions for Operability":
Change footnote reference "(a)" to "(b)."
h.
Under column entitled " Limiting Set Point":
Delete:
"(> 28" Above Core)."
5 Under Table 11.h.1.ha:
(a) Change " Requirement" to " Requirements."
(b) Change " Instrument Trip Including Valve Actuation" to
" Instrument Trip Test."
(c) Change periodicities as follows:
"Once every six months of operation other than cold shutdown" to "Once quarterly."
6.
Under Hotes for Tables 11.3.1.ha and ll.h.l.ha:
(a) Under Note (a):
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Change " steam drum" to " primary system."
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0 (b) Change Note (b) to' read:
"The primary core spray system shall be available for use during refueling operations. The backup core spray syste= shall be inoperable during refueling operations with the valves blocked or otherwise defeated (while the piping section from the valves to the reactor head is dis =antled)."
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Bases 1.
Paragraph 3:
Add:
"If a passive failure of underground fire main piping should occur _ during the long-term cooling phase, the capability exists to bypass the affected portion of piping utilizing a fire hose to ensure the continuation of long-term ECCS cooling."
2.
Paragraph 8:
Delete " vill" between " procedures" and " require."
3 Paragraphs 10 and 11 and references:
Delete in entirety.
i k.
Add nev paragraph:
"By Co==ission Memorandum and Order dated May 26, 1976 Consu=ers Power Company vas granted a plant life exemption from the require-ments of IC-CFR, Part 50, 50.h6 and Appendix K, Paragraph I.D.1 as applied to a Loss of Coolant Accident (LOCA) caused by a break in a core spray line and a concurrent single failure of a valve in the retaining core spray system. This exemption was based on conditions 4
specified in the Memorandum and Order and supporting documents, with which Consumers Power Co=pany has co=pli ed.
Thus, these Technical Specifications are in part an augmentation of these conditions."
NOTE:
Corrected Technical Specifications pages are included as /ttachment 1.
II.
Discussign In the C<,= mission's Memorandu= and Order dated May 26,~1976 three specific concerns pertaining.to the Pig Rock Point E=ergency Core Cooling Syste= (ECCS) were addressed. These included:
(1) Vulnerability to a single failure dis-abling a core spray line, following a break in the alternate core spray line; (2) T linerability to a single failure disabling the on-site power supply,
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following a Loss of Coolant Accident, in the event off-site power is unavailable; and (3) uncertainty regarding adequacy of the no::le spray distribution. Based on these concerns Consumers Power Company was required to perform specific procedural, system and component modifications as speci-fled in the Memorandu= ard Order and supporting documentation.
Prior to start-up following the 1977 refueling outage, all modifications vill be t
co=plete. The Co==ission's resolution, therefore, was granting a plant life exemption for the ECCS vulnerability to a single failure disabling a core spray line following a break in the alternate spray line and granting a limited exemption concerning the uncertainty regarding adequacy of the no::le spray distribution allowing ECCS credit for feed syste= makeup.
Fellowing the 1977 refueling outage Consumer [ Power Company vill have qualified the nozzle spray distribution through a detailed testing program and the limited exemption vill no longer be in effect.
One specific require =ent of the May 26, 1976 Memorandum and Order was to augment the surveillance of the ECCS to enhance its reliability. This re-quirement was based on both the plant life exc=ption and the li=ited exe=p-tion which gave no credit for the backup core spray distribution. On May 10, 1976 Consumers Power Co=pany requested a change to the Technical Specifica-tions for Big Rock Point which contained the aug=ented ECCS surveillance requirements. These changes were approved by the Director in Amendment 10 to the Big Bock Point Technical Specifications dated June h,1976.
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since Consumers Power Company vill qualify the backup core spray system to the satisfaction of the Co==ission, it becomes both desirable and necessary to modify the ECCS Technical Specifications to account for this.
Thts, the purpose of this change request is to update the ECCS Technical Specifications i
consistent with current industry standards based on a fully qualified backup core spray system, the limitations i= posed by the plant life exe=ption, and syste= modifications made in compliance with the Memorandum and Order a-a supporting documentation.
Prior to discussing the individual changes requested, it is prudent to discuss a Limiting Condition for Operation that vill be left intact. Specification ll.3.1.h.E of the Big Rock Point Technical Specifications requires that a
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plant shutdown be initiated within 2h hours, the reactor shutdown within 12 h
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hours, and a full plant shutdown within the following 2h hours if the following conditions cannot be met:
(1) Both core spray systems operable, (2) the core spray recirculation system operable, (3) the core sprsy re-circulation heat exchanger out of service for greater than four hours, and (h) both fire pumps (diesel and electric) and associated piping operable.
This requirement is significantly more restrictive than that imposed in current industry standards. The General Electric Boiling Water Reactor Standard Technical Specifications require restoring an inoperable core spray system component to operation within seven days prior to initiating shutdown. Maintaining this severely restrictive Limiting Condition for Operation ensures the continued safety of operation of the Big Rock Point Plant by restricting the allowable time for power operation with an inop-erable ECCS co=ponent and, therefore, adequately compensates for any margin of tclerance gained by the plant life exemption.
Under Specification 11.h.1.hA, the requirement to check the operability of MO-7051, -7061, -7066, -7073 and -70Th has been deleted. The requirement to cycle MO-7073 and -TOTh (makeup valves for water from the fire header to the main condenser) was based on the limited exemption which gave credit for the capability of the feed system to provide ECCS cooling.
Since this exemp-tion is no longer in effect, there is no longer any credit given for feed system makeup capabilities; therefore, there is no necessity to incorporate the testing of these valves under the Technical Specifications. The peri-odicity of cycling MO-7051, -7061 and -7066 has been shifted tc a refueling outage periodicity (approximately 12 months). This is still more conserva-tive than the current industry standards of 18-month system functional checks 4".cluding valve actuation.
It is determined that the requirement to cycle MO-7051 and -7061 (core spray ring isolation valves) monthly was based on enhanced surveillance of the primary core spray system since the backup system was not qualified. This determination is based on the April 19, 1976 letter from Mr Ben C Rusche to Mr Samuel J Chilk which presented the staff views regarding the Big Rock Point ECCS evaluation. Under the section en-
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titled Effectiveness of Nozzle Core Spray, the following co= ents are made-(
" Augmented surveillance of the core ring spray valves can ennance reliability sufficiently for a limited period of operation such as 5
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. the next refueling period.. However, for the long-term. operation the staff believes that redundant spray cooling systems should be provided to protect against failures in the in-core spray cooling sparger."
Thus, since the backup spray system will be qualified, the requirement for monthly valve tests is no longer necessary and should, in fact, conform to industry standards. Valve MO-7066-(post-incident heat exchanger isolation l
valve) should also fall under the standard criteria for ECCS valve testing.
It should further be noted that.since these monthly valve cycling tests have been' initiated, there have been no abnormalities noted.
An additional item deleted from Section 11.h.1.k.A is the verification that the check valve between M0-7051 and -7061 is not stuck shut.
It is apparent
' that this requirement stemmed from the concern over having only one core spray system qualified (reference the letter of April 19, 1976 from Rusche to Chilk and passage cited above).
It must also be emphasized that the re-quirement to verify that the check valve between MO-7070 and -7071 is not stuck shut does not exist in this section.' Further, the standard Technical I
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Specifications do not'contain requirements to verify check valve operability.
However, since the operability of the check valves for both the primary and '
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backup core spray systems is important to system performance, the operability check (check function) has been retained, but at refueling outage period-icity.
Since the position of certain valves is important to ECCS performance, the requirement to verify their locked position has been added to Section 11.h.l.h.A.
It should'be noted that the locked shut position of the station transformer deluge valve upstream isolation is simply an interim resolution for meeting the single failure criteria pertinent to deluge valve failure.
When a final solution.is achieved a further Technical Specifications change vill be requested.
h Section 11.h.1.h.B has been. deleted in its entirety. The valve testing specified will be accomplished at a refueling outage periodicity to be con-sistent with other valve testing. Section 11.h.l.h.C was changed to reflect this periodicity and, therefore, encompassed Section ll.k.1.h.D.
The re-quirement for calibration of core spray. system actuation circuitry was g-i a
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deleted from S6ction 11.h.1.h.D since it is contained in Tables 11.3.1.ha and 11.h.l.ha.
Section 11.31.h.F and the asterisked note under Section 11.h.1.h have been deleted since they are no longer applicable.
An additional surveillance requirement has been added.
This is to perform
.a pressure test of the backup cooling supply hose for tt.' post-incident heat This hose is' utilized only when a condition of long-term ECCS exchanger.
cooling is reached, and a pass 3ve failure in the underground fire header piping occurs.
However, since this is a safety-related component, its integrity by pressure test must be ensured. A periodicity of each refueling outage is jud ed adquate.
6 There have been several changes proposed to Tables 11.3.1.ha and 11.h.1.ha, most editorial in nature. The notes have been modified for clarity, and several typographical errors have been corrected.
One major change to
, Table 11.h.1.ha was to aug=ent the requirement for ECCS on-line testability as stipulated in the Cor=ission's Memorandum and Order. This has been done The by requiring a quarterly instrument trip test for the ECCS sensors.
system modifications for performing this test will be specified under sepa-rate cover.
Changes proposed for the Bases section of this Technical Specification con-sist of addition of information concerning the backup cooling supply hose for the post-incident heat exchanger and the plant life exemption granted by the Commission's Memorandum and Order dated May 26, 1976, and the dele-tion of information pertinent to the limited exemption.
Further, the ref-erences have been deleted as being inappropriate.
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Conclusions Bar A on the foregoing, both the Big Rock Point Plant Review Committee and the Safety and Audit Review Board have conel'ided that this change does not
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invclve an unreviewed safety question.
CONSUMERS POWER COMPANY By s
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r C R Bilby, Vice Pres @ t Production & Transmihedon Sworn and subscribed to before me this 12th day of August 1977
_t - nI ct Sy1Yia W Ball, Notary Public Jackson County, Michigan
}tr commission expires April 13, 1980 L
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