ML20080P339

Amend 163 to License DPR-20,revising PCS pressure-temp limits,power-operated Relief Valve Setting & PCP Starting Limits to Accommodate Reactor Vessel Fluence for Addl 4 EFPY

ML20080P339
Person / Time
Site:	Palisades
Issue date:	03/02/1995
From:	Hannon J NRC (Affiliation Not Assigned)
To:
Shared Package
ML20080P342	List: ML20080P339 ML20080P349
References
NUDOCS 9503070323
Download: ML20080P339 (21)

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UNITED STATES 1 NUCLEAR REGULATORY COMMISSION' in

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waswiwarow, o.c. sonese -

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?9*****l CONSUMERS POWER COMPANY'

. DOCKET NO.-50-255\\

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PALISADES PLANT-AMENDMENT TO FACILITY'OPtRATING LICENSE Amendment No.163 License No. DPR-20 4

1.

The Nuclear Regulatory Commission (the Commission) has found that:

p A.

The application for amendment by Consumers Power Company (the:

L licensee)' dated October 5, 1994, as supplemented February 10, 20,.and i

22, 1995 complies with the standards and requirements of the Atomic

~

Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; 8.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and. regulations of the" Commission;-

C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public; and (ii) that such activities will be conducted

-i in compliance with the Commission's regulations;

.i D.

The issuance of this amendment will not be inimical to the common defense and security or to the~ health and safety of the public; E.

The issuance of this amendment is in accordance with 10 CFR Part'51 of-the Commission's regulations and all applicable requirements' have been satisfied.

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2.

Accordingly, the license is amended by changes to the Technical

. Specifications as indicated-in the attachment.to the license amendment and a

' Paragraph 2.C.(2) of Facility Operating License.No. DPR-20 is hereby amended to read as follows:

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1 ' Technical Specifications -

The Technical Specifications: contained in Appendix A, as revised-through Amendment No.163, and the' Environmental Protection P1an '

contained in' Appendix B are hereby incorporated-in the license.

The p"

licensee shall operate the facility.'in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This license. amendment'is effective as. of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION 4

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John N. Hannon, Director Project Directorate III-I Division of Reactor Projects -=III/IV.

Office of Nuclear Reactor Regulation-

Attachment:

Changes to the Technical Specifications Date of Issuance: March 2, 1995

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-l ATTACWlENT T0' LICENSE AMENDMENT NO.163 i+

FACILITY OPERATING' LICENSE NO. DPR-20 l

DOCKET NO. 50-255 l

Revise Appendix A Technical; Specifications by removing the pages identified below and inserting the attached pages. The revised pages _ are. identified by 4

amendment number and contain vertical lines indicating'the areas ~ of change. '

BEBQy1 INSERT l

1 1

3-Id 3-Id j

3-4~

3 L, 3-5.

3-5

~l 3-6 3-6

~3-7 3-7i

3-8 3 i 3-9 3-9 3-10 3-10 l

3-11 l

3-12 3-12 3-13 3-13 j

3-25c 3-25c

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3-25e 3-25e 3-25f 3-25f i

3-25g 3-25g 3-30 3-30 3-33 3-33 i

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e PALISADES PLANT TECHNICAL SPECIFICATIONS y,

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TABLE OF CONTENTS SECIl0N DESCRIPTION PAGE NO 11.0 DEEIMIPRE 1-1 1.1 OPERATING CONDITIONS 1-1 l

.1.2 MISCELLANE0US DEFINITIONS 1-5 2.0 SAFETY LIMITS AND LIMITING SAFETY SYSTEM SEUJgg 2-1 2.1 SAFETY LIMITS - REACTOR CORE 2 2.2' SAFETY LIMITS - PRIMARY COOLANT SYSTEM PRESSURE 2-l' i

2.3 LIMITING SAFETY SYSTEM SETTINGS - RPS 2-1 Table 2.3.1 Reactor Protective System Trip Setting Limits 2-2

.B2.1 Basis - Reactor Core Safet Limit 82-1 82.2 Basis - Primary Coolant 3 tem Safety Limit 82-2 B2.3 Basis - Limiting Safety S stem Settings 82-3 3.0 LIMITING CONDITIONS FOR OPERATION 3-1 3.0 APPLICABILITY

' 3-l' 3.1 PRIMARY COOLANT SYSTEM 3-1b 3.1.1 Operable Components 3-lb Figure 3-0 ASI. Limit for T w function 3-3a 1

3.1.2 Pressure-Tempera 6reLimits 3-4 Figure 3-1 Pressure - Temperature Limits for Heatup 3 Figure 3-2 Pressure - Temperature Limits for Cooldown 3-6 i

3.1.3 Minimum Conditions for uiticality 3-12 3.1.4 Maximum Primary Coolant Radioactivity 3-17 3.1.5 Primary Coolant System Leakage Limits 3-20 i

3.1.6 Maximum PCS 0xygen and Halo en Concentration 3-23 3.1.7 Primary and Secondary Safa Valves 3-25 3.1.8 Over Pressure Protection 5 tems' 3-25a Figure 3-4 LTOP Limit Curve 3-25c l

l 3.1.9 Shutdown Cooling 3-25h 3.2 CHEMICAL AND VOLUME CONTROL SYSTEM 3 !

3.3 EMERGENCY CORE COOLING SYSTEM

,3-29 3.4 CONTAINMENT COOLING 3-34 3.5 STEAM AND FEEDWATER SYSTEMS 3-38 3.6 CONTAINMENT SYSTEM 3-40 Table 3.6.1 Containment Penetrations and Valves 3-40b 3.7 ELECTRICAL SYSTEMS 3-41 3.8 REFUELING OPERATIONS 3-46

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3.9 Deleted 3-49 a

Amendment No. 162, 163 m.-

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• lPRIMARYCOOLANTSYSTEM-N, j

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-Doerable Components (continued):

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Forced circulation!(starting lthe first primary coolantipumf).. shall:

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not be initiated unless one:of the following conditio'ns ;is met: ~ '

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PCS cold leg temperature (T,)11s > 430*F;

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q (2) S/G secondary temperature 1s s T,.

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-(3)z S/G. secondary temperature is < 100*F ab'o've;T,,..and a

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shutdown cooling is; isolated from.the PCS, and-9 PCS heatup/cooldown rate is s 10'F/ hour. '

1 (4) S/G secondary temperature tis < 100'F above T,, and pp shutdown cooling is isolated from the. PCS, and

pressurizer level is s 57%.

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-1.

When the'PCS cold leg temperature is < 300*F, primary coolant pumpsi j

P-50A and,P-50B shall not be operated simultaneously..

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- The ' PCS shall - not be. heated' or. maintained.above 300*F unlessja-minimum of 375 kW of pressurizer heater capacity isfavailablelfrom' both buses ID and 1E.

Should heater capacity from either bus ID. or- )

IE fall: below.375 kW, either restore the inoperable heaters toz provide at least 375 kW of heater capacity from both buses.lD and 4

..ll.

1 IE within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in HOT SHUTDOWN within.the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.-

I Basis j

When primary coolant boron concentration.is being changed,- the process must be uniform throughout-the primary coolant l system volume to prevent-3 stratification of_ primary coolant at lower boron concentration which could; result in a reactivity insertion. Sufficient mixing of the' primary. coolant is i

assured if one shutdown' cooling or one-primary coolant pump,is.in' operation."' The shutdown cooling pump will circulate. the. primary" system j

volume in less than 60 minutes when operated at rated capacity.

Bysimpos_ing=

i a minimum shutdown. cooling pump flow rate of 2810 gpm, sufficient time is J

provided for the 0,perator to terminate the boron dilution under asymmetric flow conditions.'3 The pressurizer volume is relatively inactive, Ltherefore

,a will tend to have a boron concentration higher than rest.of the. primary coolant system during:a dilution operation. Administrative procedures-will 1

provide for use of pressurizer sprays-to maintain a nominal spread between j!

the boron concentration'in the pressurizer and-the primary system during the j

addition of boron.<2)

The 57% pressurizer level, in section 3.1.lh(4),- is' not an analytical" result,

.i but simply a decision point.between having and not having a bubble.

It was chosen to agree with the maximum programmed level during power operation.-

The limitation, in section 3.1.11, on operating P-50A and P-50B together with.

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T, below 300*FL allows the Pressure Temperature-limits of Figures 3-l' and 3-2 to be higher than they would be without this limit.

3-Id Amendment No. H, 85, W, H8, W, W, 163,

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3.1 PRIMARY COOLANT SYSTEM Specification'

.3.1.2 PCS pressure, PCS temperature, and PCS heatup and.cooldown rates shall be maintained within the following limits-

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a.

The primary coolant system (PCS) pressure shall be maintained within the limits of Figures 3-1 and 3-2.

b.

The pressurizer heatup and cooldown rates be maintained s 100*F/ hour **.

c.

The primary coolant system (PCS) heatup and cooldown rates be maintained within the following limits.

Reactor Vessel-Inlet Temperature (T)

Heatuo Rate Limit

[goldown Rate Limit T 5 170*F 20*F/ hour 40*F/ hour 250 2 T > 170*F

-40*F/ hour 40'F/ hour 350 > T > 250*F 60*F/ hour **

60'F/ hour T 2 350*F 100*F/ hour 100*F/ hour

• • When shutdown cooling isolation valves M0-3015 and MO-3016 are -

open, PCS heatup rate shall be maintained s 40*F/ hour and the pressurizer heatup rate shall be maintained s 60*F/ hour.

Aeolicability Specification 3.1.2 applies at all times.

Action a.

If the limits of Specification 3.1.2 are exceeded:

1.

Return to within limits within 30 minutes, and 2.

Determine that the PCS condition is acceptable for continued operation within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

b.

If any action required by 3.1.2a is not met and the associated completion time has expired:

1.

The reactor shall be placed in HOT SHUTDOWN within 12 hot,rs, and 2.

The reactor shall be placed in a COLD SHUTDOWN with PCS U

pressure less than 270 psia, within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

j 3-4 Amendment No. N, 44, 66, 89, W, W, 484, 163 j

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Pressure-Temperature Limits 1

for Heatup i

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3-5 Amendment No. N, 44, 55, 89, 97, W, m,163

Figure 3-2 Pressure-Temperature Limits for Cooldown-2500-I A

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I 3-6 Amendment No. N, 4, H, 69, W, 4W, 4M,163

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'[3.1 PRIMARY C00LANT SYSTEM I

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. bBhis-pressure'Temperaturelimits:

't The Primary Coolant System Pressure-Tempeyture limits are calculated for a o

! reactor vessel. wall fluence of 2.192 x 10.nyt. Before the radiation ~

. exposure 'of the reactor vessel exceeds that fluence, Figures 3-1.and 3-2 1

shall be updated in accordance with the following criteria and' procedure-r 1.

US Nuclear Regulatory Commission Regulatory Guide 1.99 Revision 2 has been used to predict the increase in transition temperature based on integrated fast. neutron flux and surveillance test data.

If

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measurements on the irradiated specimens'show increase above this curve, a new curve shall be constructed such that it is above and to the left 1

of all applicable data points.

2.

Before the end of the integrated power period for which Figures-3-1 and 3-2 apply, the limit lines on the figures shall be updated for a new.

integrated power period. The total-integrated reactor thermal' power from-start-up to the end of the new power period shall be converted to an equivalent integrated fast neutron exposure (E t 1 MeV). Such a conversion ~shg1 be made consistent with the dosimetry evaluation of capsule W-290

.i 3.

The limit lines in Figures 3-1 and 3-2 are based on t'he requirements of-Reference 9, Paragraphs IV.A.2 and IV.A.3.

All components in the primary coolant system are designed to' withstand-the changes.gf, cyclic loads due to primary system temperature and pressure effects These cyclic loads are introduced by nomal unit load transients, l

reactor trips and start-up and shutdown operation. During unit start-up and 1

shutdown, the rates of temperature and pressure changes are limited.

A i

maximum plant heatup and cooldown limit of 100*F per hour is consistent with 1

operation.g) umber of cycles 'and satisfies stress limits for cyclic.

1 the design The reactor vessel plate and material opposite the core has been purchased to a specified Charpy V-Notch test result of 30 ft-lb or greater at an NDTT of +'

10'F or less.- The vessel circumferential. weld has the highest RT of l

plate,' geld and HAZ materials at the fluence to which the Figureh An R 1 and 3 '

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apply.

The unirradiated RT has been determined to be -56*F..

of-56*FisusedasanunirraEatedvaluetowhichirradiation'effectsar.,

e added.. In addition,- the plate has been 100% volumetrically inspected. by-ultrasonic test using both longitudinal and shear wave methods. The i

remaining material in the reactor vessel, and other primary coolant system components, meets the appropriate design code requip 8..ts and specific component function and has a maximum NDTT of +40*F.

As a result of fast neutron irradiation in the beltline region of the core, there will be an increase in the RT, with operation.

The integrated fast neutron (E >l MeV) fluxes of the reacIor vessel are contained in Reference 13.

1 3-7 Amendment No. N, 44, 65, 89, W, 4W, M4,163

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13.11 PRIMARY CIMILANT SYSTEM j

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. Basis '- Pressure Tennerature Limits: (continued) -

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Since the tatron' spectra and the flux measured at the samples and reactor

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vessel inside radius should be nearly identical, the measured transition l

shift from a sample can be applied to the adjacent section of the reactor.

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vessel for later stages in plant life _ equivalent to the difference in

. calculated flux magnitude. The maximum exposure of the reactor vessel will l

be obtained from the measured sample exposure by application'of the

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calculated azimuthal neutron flux variation. The predicted-RT shift for Regulatory Guide. gen predicted based upon surveillance data., d the U the base metal ha an To compensate for any increase in the RT 1rradiation, limits on the pressure-temperature relationship., caused by -

j are periodically-a changed to stay within the stress limits during heatup and cooldown..

Reference 7 provides a procedure for obtaining the allowable loadings for.

0 ferritic pressure-retaining materials in Class I components. This procedure is based on the principles of linear elastic fracture mechanics and involves a stress intensity factor prediction which is a lower bound of static,

.l dynamic g crack arrest critical values. The stress intensity factor l

computed is a function of RT,, operating temperature, and vessel wall temperature gradients.

l Pressure-temperature limit calculational procedures for the reactor coolant l

pressure boundary are defined in Reference 8 based upon Reference 7.

The i

limit lines of Figures 3-1 and 3-2 include an allowance to account for the.

l l

fact that pressure is measured in the pressurizer rather than at the vessel beltline and to account for PCP discharge pressure.

In addition, for j

calculational purposes, 5'F and 30 psi was taken as measurement error i

allowances for calculation of criticality temperature. By Reference 7,'

l reactor vessel wall locations at 1/4 and 3/4 thickness are limiting.

It is at these locatiens that the crack propagation associated with the hypothetical flaw must be arrested. At these locations, fluence attenuation i

and thermal gradients have been uvaluated. During cooldown, the 1/4 thickness location is always more limiting in that the RT is higher than 1

that at the 3/4 thickness location and thermal gradient sEesses are tensile i

there. During heatup, either the 1/4 thickness or 3/4 thickness location may i

be limiting depending upon heatup rate.

j Figures 31 and 3-2 define stress limitations only from a fracture mechanics l

point of view.

l 4

Other considerations may be more restrictive with respect to pressure-temperature limits.

For normal operation, other inherent plant i i

characteristics may limit the heatup and cooldown rates which can be e

achieved. Pump parameters and pressurizer heating capacity tends to restrict both normal heatup and cooldown rates to less than 60*F per hour.

i 3-8 l

Amendment No. N, 44, 66, 89, N, M. E,163 j

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3.1-PRIMARY COOLANT SYSTEM 1.,-

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. Basis - Pressere Temnerature Limits:

(continued)

.l The revised pressure-temperature limitsgre ' applicable to reactor vessel-l

. inner wall fluences of up to 2.192 x 10 nyt. The application of appropriate-l i

fluence attenuation factors-(Reference 10) at the 1/4 and 3/4 thickness locations results in RT limiting weld material shifts of 255*F and 191*F, respectively, for the '

.F l

The criticality condition which defines a temperature below which the core I

cannot be made critical (strictly based upon fracture mechanics

• l considerattens) is 385*F. - The most limiting wall location 1s at 1/4-thickness. The minimum criticality temperature 385*F-is the minimum permissible temperature for the inservice system hydrostatic. pressure test.

That temperature is calculated based upon 2310 psig inservice hydrostatic test pressure.

The restriction of average heatup and cooldown ratet: to 100*F/ hour when all l

PCS cold legs are 2 350*F and the maintenance of a pressure-temperature relationship under Figures 3-1 and 3-2 ensures that the requirements of l

References 7, 8 and 9 are met. Calculation of average hourly cooldown rate must consider changes in reactor vessel inlet temperature caused by:

initiating shutdown cooling, by starting primary coolant pumps with a temperature difference betwee.. the steam gmerator and PCS, or by stopping primary coolant' pumps with shutdown cooling in service...

j The heatup and cooldown rate restrictions are consistent with the analyses l

performed for low temperature overpressure protection (LTOP) (Reference 14). Below -

430*F, the Power Operated Relief Valves (PORVs) provide overpressure.

protection; at 430*F or above, the PCS safety valves provide overpressure protection.

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3-9 l

Amendment No. N, 44, H, 89, W, W, H+,163 i

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Basis - Pressure Temnerature Limits-(continued)-

References (1) FSAR,-Section 4.2.2.-

L(2) ASME Boiler and Pressure. Vessel. code,Section~.III, A-2000..

(3) Battelle Columbus Laboratories Report, " Palisades Pressure Vessel

.i Irradiation Capsule Program: Unirradiated Mechanical Properties,"

August 25, 1977.

/

(4) Battelle Columbus: Laboratories Report, " Palisades Nuclear Plant Reactor; Vessel Surveillance Program: Capsule A-240," March 13,1979, ' submitted i

to the NRC by Consumers Power Company letter dated July 2, It'9e (5) FSAR, Section 4.2.4.

(6)

(Deleted).

(7) ASME Boiler and Pressure Vessel Code,Section III, Appendix G, t

" Protection Against Non-Ductile Failure," 1974 Edition.

'(8) US Atomic Energy Commission Standard Review Plar., Directorate of i

Licensing, Section 5.3.2, " Pressure-Temperature Limits."

(9) 10 CFR Part 50, Appendix G, " Fracture Toughness Requirements," May 31, 1983 as amended November 6,1986.

(10) US Nuclear Regulatory Commission, Regulatory Guide 1.99, Revision 2,.

l May, 1988.

(11) Combustion Engineering Report CEN-189, December, 1981.

a (12) " Analysis of Capsules T-330 and W-290 from the Consumers Power Company.

l Palisades Reactor Vessel Radiation Surveillance Program," WCAP-10637, September, 1984.

)

. (13) Consumers Power Company letter to NRC, June lo, 1993; 10CFR50.61 Pressurized Thermal Shock - Reactor Vessel Neutron Fluence - Additional l

Infomation.

I 1

(14) Consumers Power Company Engineering Analysis EA-A-PAL-92095-01, Rev 0; "PressureTemperatureCurvesjndLTOPLigitCurveforMaximumReactor Vessel Fluence of 2.192 x 10 Neutron /cm "

(Next Page 3-12) 3-10 l

Amendment No. N, 41, 55, 69, 97, 4W, 4H,163

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l3.1 PRIMARY COOLANT SYSTEM i

9 s.

.3.1.3 -

Minimum Conditions for Criticality l

a)~ 'Except during low-power physics test, the reactor shall not be.made -

J critical if the primary coolant _ temperature is below 525'F.

b)

In no case shall the reactor be made critical if the primary coolant temperature is below 385*F.

~l i

c)

When the primary r71 ant temperature is below the minimum:

l temperature specifled in "a" above, the reactor shall be i

subcritical by an amount equal to or greater than the potential i

reactivity insertion due to depressurization.

~d)

No more than one control rod at a time shall be' exercised or -

withdrawn until after a stem bubble and normal water level are i

established in the pressurizer.

t e)

Primary coolant boron concentration shall not be reduced until

)

after a steam bubble and normal water level are established in the pressurizer.

1A111 At the beginning of life of the initial fuel cycle, the moderator temperature.

coefficient is' expected to be si with all control rods withdrawn.ghtly negative at operating temperatures However, the uncertainty of the i

calculation is such that it~is possible that a slightly positive coefficient could exist.

i The moderator coefficient at lower tempgrg)tures will' be less negative or more' positive than at operating temperature.

It is, therefore, 4

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-l 3-12 I

Autendment No. N, 44, 66, 89, N, 4 W,-163 l

j 3.1 PRIMARY C0OLANT SYSTEM l

y 3.1.3

' Minimum Conditions for Criticality - (Cont'd) 1 B3111 (Cont'd)-

prudent to restrict the operation of the reactor'when primary coolant t

temperatures are less than normal operating temperature (1525'F). Assuming-the most pessimistic rods out moderator coefficient, the maximum potentia reactivity insertion that could result from depressurizing the coolant from 2100 psia to saturatioh pressure at 525'F. is 0.11r, Ap.

Duringphysicstests,specialoperatingprecautioy)willbetaken.

In addition, the strong negative Doppler coefficient and the small integrated ~

As would limit the magnitude of a power excursion resulting from a reduction of moderator density. The requirement that the reactor is not to be made critical below 385'F provides increased assurance that the proper '

relationship between primary coolant pressure and temperature will be enintained relative to the RT,his temperature will be accomplished by of the primary coolant system pressure l

boundary material. Heatup to t operating the primary coolant pumps.

I If the shutdown margin required by Specification 3.10.1 is maintained, there is no possibility of an accidental criticality as a result of an increase of moderator temperature or a decrease of coolant pressure.

l Normal water level is established in the pressurizer prior to the withdrawal of control rods or the dilution of boron so as to preclude the possible

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overpressurization of a solid primary _ coolant system.

1 References (1)

FSAR, Table 3-2 (2)

FSAR, Table 3-6 (3) FSAR, Table 3-3 i

(Next page is 3-17) 3-13 Amendment No. H, W, 163

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Figure 3-4 LTOP Setpoint LIMIT 2500 1

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2000 1750 v>

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250 y v v v v v v v v v v v v v v v v v v v v v v v v v v y

,, u 50 100 150. 200 250 300 350 400 450 PCS Temperature, F 3-25C Amendment No. AH,163

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3.1.8 -

DVER PRESSURE P30TECTION SYSTEMS jnit 3.1.8.1

~(continued)

Normally, during operation at HOT STANDBY and above, the PORV' controls are in the CLOSE position, and the block valves are closed. The PORVs, block' j

valves, and the associated manual controls must be operable.

If either valve in a PORY flow path is inoperable, the other valve in the flow path must provide PCS integrity assurance. When a PORY is inoperable, the block valve.

j must be closed; when a block valve is inoperable, the PORV aust have its control in the "CLOSE" position.

If the inoperable valves cannot be restored to OPERABLE status within the specified completion time, the plant must be placed in HOT SHUTDOWN. The completion times allow the required action to be accomplished without undue haste, yet allow less time when more equipment is inoperable.

Basis 3.1.8.2 When PCS is below 430*F with the reactor vessel head installed, two PORVs are required to be operable to avoid pressures which might lead to failure of the reactor vessel. Pressure increases could be caused by sudden additions (or imbalances) of either mass or energy.

The allowable pressure limits are determined in accordance with 10 CFR 50,

~

Appendix G, and are referred to as " Low Temperature Overpressure Protection" (LTOP) limits. The variable setpoint of the LTOP system is arogrammed and calibrated to ensure opening of the pressurizer PORVs when tie PCS pressure is above the limit in Figure 3-4.

The pressure ~ limit for each temperature is developed from the heating or cooling limits for the PCS.

The limit in Figure 3-4 includes an allowance for pressure overshoot during the interval between the time pressurizer pressure reaches the limit, and the time a PORV opens enough to terminate the pressure rise.

LTOP is provided by two independent channels each consisting of measurement, control, actuation, and valves. Either channel is capable of providing full protection. The actual setpoint of PORY actuation for LTOP will be below the limit in Figure 3-4 to allow for potential instrument inaccuracies, and drift. This will ensure that at no time between calibration intervals will the PCS pressure exceed the limit of Figure 3-4 without PORV actuation.

Mass additions could come from the starting of pumps or from opening a Safety Injection Tank isolation valve. Only the charging pumps or high pressure safety injection pumps could cause the PCS pressure to exceed its limits.

Neither the shutoff head of the low pressure stfety injection pumps nor the l

operating pressure of the safety injection tanks is above the cold PCS pressure limit. Specification 3.3.5 places limits on HPSI pump operability when the PCS is below 300*F to assure inadvertent starting does not cause overpressurization of the PCS.

i l

3-25e Amendment No. W, m, MG,163

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DVER PRES $URE PROTECTION SYSTEMS s.s

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33111

.3.1.8.2

-(continued) ed Energy'additionscouldcomefromeitherthesteamgeneratorsor_fromthe o

reactor core. 'Small energy addition could come from operation of the-d pressurizer heaters. Energy addition from the steam generators could occur if:

(

a primary coolant pump was started when the steam generator-secondary i

~

m

, temperature was significantly above the PCS temperature. Specification :

3.1.1.h places: limits on the starting of primary coolant pumps to avoid

.l undesired energy additions from the.. steam generators. Energy addition from

)

a the reactor core rould occur due to an inadvertent criticality or to an.

imbalance in decay heat removal. Specification 3.10.1: places limits on shutdown margin to avoid a rod withdrawal event causing a criticality _ and to.

1 4

provide sufficient' time for operator action to teminate a dilution event' 1

prior to criticality.

The potential causes of a. sudden PCS pressure increase which the LT0P system 1

must be able to mitigate are imbalance in charging and letdown flow, starting-of the HPSI pumps when above 300'F, and in an imbalance in decay heat (and l

j pressurizer heat) addition and removal. A Safety Injection Signal (5 S) could both initiate flow fros'two HPSI pumps (when above 300*F) and t ree l

charging pumps, and isolate letdown. The PCS heatup from a loss of shutdown cooling event occurring 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after shutdown from a continuous full power run would generate less additional coolant volume than the starting of three charging pumps ~(Reference 5). The limiting event for the LTOP system would be an inadvertent SIS occurring during an established _ PCS heatep.-

j Analysis (Reference 1) has concluded that an SIS occurring, during a-PCS and pressurizer heatup at the maximum allowable rates, either between 300*F and-430'F with the HPSI pumps, or below 300*F.without the HPSI. pumps,'would not.

i cause PCS pressure to exceed the Appendix G limit if either PORY opens when 1

the set pressure is reached. With the PCS above 430'F, the pressurizer safety valves, required by Specification 3.1.7,' provide ' adequate overpressure protection.

Both PORVs are required _ to be operable to allow for a single.

failure.

i If a PORY becomes inoperable when it is required for LTOP, it must be restored to operable status, or the plant must be cooled down, depressurized, and vented through a vent path with sufficient capacity to provide the necessary protection.

Since the pressure response to a transient is greater if the pressurizer steam space is small or if PCS is solid, the allowed-outage time for a PORV flow path out of service is' shorter. The maximum pressurizer level at which credit can be taken for having a bubble. (571r,,

which provides about 700 cubic feet of steam space)'is. based on judgement rather than on analyses. This level provides the same steam volume to dampen pressure transients as would be available at full power. This steam volume provides time for operator action, if the PORVs failed to operate, between an j

inadvertent SIS and PCS pressure reaching the 10 CFR 50 Appendix G pressure i

limit. The time available for action would depend upon the existing pressure and temperature when the inadvertent SIS occurred.

1 i

3-25f l

Amendment No. M, W MG,163

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g,-._.. -.

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c

. ' 3.1.8 -

prER PRESSURE PRDTECTION SYSTEMS i

4 Rasis 3.1.8.2 (continued):

~; '

(

Reference 1-has' determined that any vent path capable of relieving 167 gps at:

'i a PCS pressure of 315 psia is. acceptable. The'167 gpa flow rate is based on r

an assumed charging imbalance due to interruption of letdown flow with three charging pumps operating, a 40'F per hour PCS heatup rate, a 60*F per hour-pressur' rermeatup rate, and an initially depressurized and vented PCS.- The 1

SCS heatap rate is limited to 40*F per hour by Specification 3.1.2c; the--

1 pressurizer heatup rate is limited to 60'F per hour by Specification 3.1.2b.

Neither HpSI pump nor PCP starts need to be assumed with the PCS initially

'depressurized, because Specification 3.3.5 requires both HPSI pumps to be l

F incapable of injection-into the PCS and operating procedures prohibit PCP ja operattom.

i The pressure relieving ability of a vent path depends not' only upon the area i

of the vent opening, but also upon the configuration of the' piping connecting the vent opening to the PCS. A long, or restrictive pioing connection may prevent a larger vent opening from providing adequate flow, while a smaller opening lassediately adjacent to the PCS would be adequate. The areas of multiple vent paths cannot simply be added to determine the necessary vent area.

The following vent path examples are acceptable:

1.

Removal of the reactor vessel head, 2.

Removal of a steam. generator primary manway,

.l 3.

Removal of the pressurizer manway, 4.

Removal of a PORY or pressurizer safety valve, S.

Both PORVs and associated block valves open, 6.

Opening of both PCS vent valves PC-514 and PC-515.

h Reference 2 determined that venting the PCS through PC-514 ano PC-515 t

provided adequate flow area. The other listed examples provide greater flow.

4 areas with less piping restriction and are therefore acceptable. Other vent paths shown to provide adequate capacity could'also be used.

One open PORV provides sufficient flow area to prevent excessive PCS 3

pressure.

However, if the PORVs are elected as the vent path, both valves must be used to meet the single failure criterion, since the PORVs are held open against spring pressure by energizing the operating solenoid.

When the shutdown cooling system is in service with MO-3015 and M0-3016 open, additional overpressure protection is provided by the relief valves on the shutdown cooling system. References 3 and 4 show that this relief capacity-will prevent the PCS pressure from exceeding its pressure limits during any of the above mentioned events.

References 1.

Consumers Power Company Engineering Analysir, EA-A-PAL-92095-01 2.

Consumers Power Company Engineering Analysis, EA-TCD-91-01-01.

3.

Consumers Power Company Engineering Analysis, EA-PAL-89-040-1 4.

Consumers Power Company Corrective Action Document, A-PAL-91-Oli 5.

Consummers Power Company Engineering Analysis, EA-AG-93-02 4

3-25g Amendment No. W, m, M G,163

m Q;.

m 3.s

, 3.3 '

EMERGENCY CORE COOLING SYSTEM (Continued) 3.3.3-Prior to returning to the Power Operation Condition after every time the plant has been placed in the Refueling Shutdown Condition, or the Cold.

Shutdown Condition for more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and testing of Specification 4.3.h has not been accomplished in the previous g months, or prior to~

returning the check valves in Table 4.3.1 to service after maintenance, repair, or replacement, the following conditions shall be met:-

All pressure isolation valves listed in Table 4.3.1 shall.be a.-

functional as a pressure isolation device, except as specified in

b. Valve leakage shall not exceed the amounts indicated.

b.

In the event that integrity of any pressure isolation valve specified in Table 4.3.1 cannot be demonstrated, at least two valves in each high pressure line having a non-functional valve must be~in and remain in, the mode corresponding to the isolated-condition.g)

' Motor-operated valves shall be placed in the closed position and power supplies deenergized.

3.3.4 Two.HPSI. pumps shall be operable when the PCS temperature is >325'F.

a)

One HPSI pump may be inoperable provided 'the requirements of.

Section 3.3.2.c are met.

1 j

3.3.5 Two HPSI pumps shall be rendered incapable of injection into the PCS when PCS temperature is <300*F, if the reactor vessel head is installed.

Note:

Specification 3.3.5 does not prohibit use of the HPSI pumps for emergency addition of makeup to the PCS.

1 3-30 Amendment No. H, M, G, W, W,163

y,f h.

.31 EMERGENCY CORE COOLING SYSTEM d

,11 (continued)

' demonstrate that-the maxiaum fuel clad temperatures that could occur over the.

break size spectrum are.well below the melting temperature of zirconium.

(3300*F).

-I r

Malfunction of the Low Fressure Safety Injection Flow control valve could defeat.the Low Pressure Injection feature of the ECCS; therefore, it is disabled in the 'open' mode (by isolating the air. supply) during plant 4

operation. This action assures that it will not block flow during Safety.

Injection.

a

(

The inadvertent closing of any one of the Safety Injection bottle isclation-valves in conjunction with a LOCA has not been analyzed. To provide assurance that this will not occur, these valves are electrically locked open by a key switch in the control room.

In addition,. prior to critical the.

valves are checked open, and then the 430 volt breakers.are opened. Thus, a failure of a breaker and a switch are required for any of the valves to close.

-I Insuring both HPSI pumps are incapable of injecting into the.PCS when the PCS l

temperature is <300*F eliminates PCS mass additions due to inadvertent HPSI 1

pump starts. Both HPSI pumps starting in conjunction with a charging / letdown imbalance may cause 10CFR50 Appendix G limits to be exceeded when the PCS 1

temperature _is <300*F. A note is provided to assure that this specification

.]

does not cause hesitation in the use of a HPSI pump for PCS makeup.if it is~

i needed due to a loss of shutdown cooling of a loss of PCS inventory.

j Rendering the HPSI pumps " incapable of injection" means to assure that a single event cannot cause overpressurization of the PCS due to operation of the HPSI pump. Typical methods of accomplishing thir are the pulling of the HPSI pump breaker control power fuses, racking out the HPSI pump circuit breaker, or closing the manual discharge valve.

The requirement to have both HPSI trains operable above 325'F prcvides added assurance that the effects of a LOCA occurring under LTOP. conditions would be l

mitigated.

If a LOCA occurs when the primary system temperature'is less than or equal to 325'F, the pressure would drop to the level where low pressure safety injection can prevent core damage. When the PCS temperature is 2300*F and s325'F operation of the HPSI system would not cause the 10CFR50 Appendix G-limits to be exceeded nor is HPSI system operation necessary for core cooling.

References (1) FSAR, Section 9.10.3; (2) FSAR, Section 6.1, (3) FSAR, Section 14.17 (4) Letter, H.G.Shaw (ANF) to R.J.Gerling (CPCo), " Standard Review Plan Chapter 15' Disposition of Events Review for Changes to Technical Specifications Limits for Palisades Safety Injection Tank Liquid Lev 41s", April 11,1990.

3-33 Amendment No. M, H, M, M, W, M, E,163

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X:4.1 01ERPXS$URLMtDIEIEi, SYSTEM TESTS 1

L Surveillance Renuirenait;

. In ' addition to the. requirements of 5pecification 4.0.5, each PORV flow l path shall.be demonstrated OPERABLE.>y:

i

).

Testing the PORVs'in accordance with the inservice inspection Li requirements for-ASME Boiler and Pressure Vessel Code, Section~XI, 1

Section.IWV, Category 8 valves.

i 2.

Performance of a CHANNEL CALIBRATION on the PORV actuation channel-at least once per 18 mon 3hs.

1 3.

When the' PORV flow path'is raquired to' be OPERABLE by Specification '

[

3.1.8.1:

(a)

Performing _ a_ _ complete cycle of the PORV with the plant above'

- COLD SHUT @WN at least once per 18 months.

t (b)

Performing a complete cycle of the block valve prior to heatup-from COLD SHUTDOWN, if not cycled within 92 days.

l 4.

When the PORY flow path is required to be OPERABLE'by Specification' 3.1.8.2:

~

(a)

Performance of a CHANNEL FUNCTIONAL TEST on the PORV actuation.

channel, but excluding valve operation, at least once per 31

' days, t

(b) Verifying the associated block valve is open at least once per-72 hours.

t 5.

Both Hi h Pressure Safety Injection pumps shall be verified t

incapab e of injection into the PCS at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

l unless the reactor head is removed, when either PCS cold leg temperature is <300*F, or when both shutdown cooling suction l

valves, M0 3015 and M0-3016, are open.

~

L BA111 i

With the reactor vessel head installed when the PCS cold leg temperature is-i less than 300*F, or if the shutdown cooling system isolation. valves M0-3015 l

j and MO-3016 are open, the start of one HPSI pump could cause-the ' Appendix G i

or the shutdown cooling system pressure limits to be exceeded; therefore, both pumps are rendered inoperable.

P I

l i

Amendment No. 130, 10, 10, Me,163 i

4-6 u.

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