ML20203F646

Application for Amend to License DPR-6,changing Tech Specs Re Alternate Shutdown Battery Sys Operability & Surveillance Requirements

ML20203F646
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	04/21/1986
From:	Buckman F CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML20203F640	List: ML20203F634 ML20203F646 ML20203F652
References
NUDOCS 8604250205
Download: ML20203F646 (11)

Text

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CONSUMERS POWER. COMPANY Docket 50-155 Roquest for Change to the Technical Specifications License DPR-6 For the. reasons hereinafter set forth, it is requested that the-Technical 4

Specifications contained in the Facility Operating License DPR-6, Docket 50-155, issued to Consumers Power Company on May 1, 1964,~ for the Big Rock Point Plant be changed as described.in Section I below:

I. CHANGES A. Table of Contents Revise Section 12.0 of the Table of Contents to read as follows:

i "12.~0 Fire Protection Program ........................ 150-157d (Section 3.3.3.8/4.3.3.8) Fire Detection  !

Instrumentation ............................ 150-151 3

(Section 3.7.'11.1/4.7.11.1) Fire Suppression Water System ................... 152-153 (Section 3.7.11.2/4.7.11.2) Fire i

Spray / Sprinkler Systems .................... 154 (Section 3.7.11.5/4.7.11.5) Fire Hose 3

Stations ................................... 155 (Section-3.7.12/4.7.12) Penetration Fire ,

Barriers ................................... 156 '

(Section 3.7.13/4.7.13) Alternate

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Shutdown System ............................ 157-157b I

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Bases .......................................... 157c-157d B. Section 11.3.5.3 and 11.4.5.3 Add the Alternate Shutdown Battery System to the specification for Emergency Power Sources as follows:

11.3.5.3 EMERGENCY POWER SOURCES "A. For all reactor operating conditions except cold ,

shutdown, there shall normally be available one 138 kV line, one 45 kV line, one diesel generator system, one station battery system, four RDS uninterruptible

-power supplies including batteries and one alternate shutdown battery system, except as specified below:"

"A. 5. . The station battery system and the alternate shutdown battery system shall be operable under all conditions except during cold shutdown. If

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8604250205 PDR * *I *** * * *"

ADOCK 50 #* * ** "

• P 55 which result in a reactivity addition, except pg nd cooldown, or which might result in the primary coolant system being drained."

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-Big Rock Paint Plcnt 2 TSCR - Alternate Shutdown System 11.4.5.3 EMERGENCY POWER SOURCES "A. 1.(e) Verify the cells, cell plates, and battery racks show no visual indication of physical damage or abnormal deterioration for the station battery, the RDS batteries and the alternate shutdown battery.

"A. 1.(f) Verify the cell-to-cell and terminal connec-tions are clean, tight, free of corrosion and coated with anti-corrosion material for the station battery, the RDS batteries, and the alternate shutdown battery."

"A. 1.(h) Verify that the capacity of the station battery, the RDS batteries and the alternate shutdown battery is adequate to supply and maintain in OPERABLE status all of the actual emergency loads for the design time interval when the battery is subjected to a battery service test. The design time interval for the RDS batteries is one hour, eight hours for the station battery and eight hours for the alternate shutdown battery."

"A. 2.(b) Verify that the cell voltage is 22.0 volts and specific gravity is 21.2 of each cell of the station battery; and verify that the cell voltage is 26.0 volts and specific gravity is 21.2 on each cell of the RDS batteries; and verify that the cell voltage is 22.1 volts and specific gravity is 21.2 of each cell of the alternate shutdown battery."

"A. 3.(a) Verify the electrolyte level of each RDS battery pilot cell, the station battery pilot cell and the alternate shutdown battery pilot cell is between the minimum and maximum level indication marks.

(b) Verify the pilot cell specific gravity for RDS, station and alternate shutdown batteries corrected to 77'F, is 21.2.

(c) Verify the station battery pilot cell voltage is 22.0 volts, the RDS battery pilot cell voltage is 26.0 volts and the alternate shutdown battery pilot cell voltage is 22.1 volts.

(d) Verify the overall battery voltage is 2125 volts for the station battery, the RDS batteries and the alternate shutdown battery."

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$. a Big R ck Point Plcnt . , 3 TSCR - Alternate Shutdown System "A. 5 Sixty Months - At least once per 60 months during L shutdown, verify that the 'IU)S batteries, the

' alternate shutdown battery and the station

! battery capacity is at least 80% of the manufac-turer's rating when subjected to a performance L discharge.. test. This performance discharge test shall be performed subsequent to the satisfactory l completion of the required battery service test p of Part 11.4.5.3.A.1.(h)."

C .- Bases for Section 11.3.5.3 and 11.4.5.3 L

l Add the following:

"The alternate shutdown battery supplies power to the main steam i isolation valve, the emergency condenser outlet valves and other alternate shutdown equipment. The battery is sized such that loss l of the charger does not affect operability of the battery for up to six (6) days at a minimum of 25*F (nine (9) days at minimum of 40'F)."

D. Section 3.3.3.8 l

Add to Table 3.3-8, the smoke detection instruments for the Alternate Shutdown Building, as follows:

"13. Alternate Shutdown Building 2 -

1" E .' Section 3/4.7.12 Change the Limiting Conditions for Operation to read as follows:

"3.7.12 All penetration fire barriers including fire doors and fire

. dampers protecting safety-related areas shall be functional."

F. Section 3/4.7.13 Add the following specifications for the alternate shutdown system:

l i

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g' a' Big Rock Point Plcnt 4 TSCR - Alternate Shutdown System

" PLANT SYSTEMS 3/4.7.13 ALTERNATE SHUTDOWN SYSTEM LIMITING CONDITIONS FOR OPERATION 3.7.13 The alternate shutdown system (ASD) equipment shown in Table 3.3.9 shall be OPERABLE.

APPLICABILITY During power operation.

ACTION

a. With any item, other than the #1 control rod drive pump, its associated ASD power source or the two emergency condenser indicating lights, in Table 3.3.9 inoperable, either restore to

, OPERABLE status within 7 days or a normal orderly shutdown shall be initiated within one (1) hour and the reactor shall be shutdown as described in Section 1.2.5(a) within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and shutdown as described in Section 1.2.5(a) and (b) within the l following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

I l b. With the #1 control rod drive pump, its associated ASD power source or either of the two emergency condenser indicating lights inoperable, either restore to OPERABLE status within 60 days or a normal orderly shutdown shall be initiated within one (1) hour and the reactor shall be shutdown as described in Section 1.2.5(a) within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and shutdown as described in Section 1.2.5(a) and (b) within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.7.13.1 The ASD monitoring instruments shall be demonstrated OPERABLE by performing a check and a calibration per Table 4.3-9.

4.7.13.2 Each transfer svitch, power supply and control circuit shall be demonstrated OPERABLE at each major refueling shutdown

• by operating each actuated component from both the control room and the remote location.

4.7.13.3 At each major refueling shutdown

• perform a verification

! to insure that equipment (alternate power sources) needed to achieve and maintain cold shutdown is available.

• But no less than once every 18 months."

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Big R:ck Point Plcnt 5 TSCR - Alternate Shutdown System

" TABLE 3.3-9 ALTERNATE SHUTDOWN SYSTEM EQUIPMENT INSTRUMENT READOUT LOCATION

1. Steam Drum Level /LI-6819 Panel C31 2.- Steam Drum Pressure /PI-6819 Panel C31

-3. Emergency Condenser Low Level . Panel C31 Alarm Indicating Light /LS-3550 4.- Emergency Condenser Firewater Panel C31 Makeup Flow Indicating Light /FS-4947 TRANSFER SWITCHES / POWER SUPPLIES / CONTROL CIRCUITS SWITCH LOCATION

1. Emergency Condenser Outlet Valve ASD MO-7053 Motor Control MO-7053* Starter OR Emergency Condenser Outlet Valve ASD MO-7063 Motor Control MO-7063* Starter

2. Main Steam Isolation Valve control MO-7050 Motor MO-7050 Starter

3. Emergency Condenser Firewater Makeup Panel C31 Valve Control SV-4947

4. Control Rod Drive Pump No. I and Equipment Lock associated ASD Power Source

• Section 3.7.13(a) applies only if the alternate shutdown controls for both emergency condenser outlet valves, MO-7053 and MO-7063, are inoperable at the same time."

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Big Rock Point Pltnt 6 TSCR - Alternate Shutdown System

" TABLE 4.3.-9 ALTERNATE SHUTDOWN SYSTEM INSTRUMENT SURVEILLANCE REQUIREMENTS INSTRUMENT SURVEILLANCE FREQUENCY METHOD

1. Steam Drum Level. A. Check Quarterly compare to known level LI-6819 B. Calibration Every le apply known differential months pressures to transmitters

2. Steam Drum Pressure, A. Check Qunrterly compare to known pressure PI-6819 B. Calibration Every 18 apply known pressures to months transmitter

3. Emergency Condenser A. Check Quarterly initiate flow in line Makeup Line Flow Switch Indicating Light, FS-4947

4. Emergency Condenser Low A. Check Quarterly simulate low level Level Alarm Indicating Light, LS-3550 B. Calibration Every 18 apply known differential

} (Panel C31) months pressure to switch" i

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i w s Big Rock Point Plant 7 TSCR - Alternate Shutdown System G. Bases for Section 3/4.7.12 Revise the last sentence of the first paragraph to read as follows:

"The penetration fire barriers include active and passive elements in the facility fire protection program which are subject to periodic inspections."

H. Bases for Section 3/4.7.13 Add the following to the bases:

"3/4.7.13 ALTERNATE SHUTDOWN SYSTEM The requirements for the Alternate Shutdown System provide assurance that safe shutdown and cooldown to approximately 212*F can be achieved in the event of major fire in critical areas of the plant.

This capability is in accordance with the criteria of Appendix R to 10 CFR 50."

II. DISCUSSION These changes add operability and surveillance requirements for components of the alternate shutdown system installed in accordance with Appendix R to 10 CFR 50. System design we- reviewed and approved as discussed in the NRC Safety Evaluations da. 3 March 8, 1983 and March 26, 1985. The requirements are based on applicable portions of draft standard Technical Specifications. The equipment represents the minimum required to reach safe " hot" shutdown conditions for a fire that destroys the normal systems. Operability requirements on equipment required to reach " cold" shutdown was not included in the proposal for the following reasons:

1. Thi equipment included in this proposal is adequate to provide assurance that safe " hot" shutdown of the reactor can be achieved and maintained indefinitely. This involves the use of the main steam isolation valve to limit any primary system leakage, the emergency condenser to cooldown the system, and a control rod drive pump to provide makeup to the primary system. At Big Rock this condition is very stable. The reactor can be maintained in safe shutdown status indefiettely under these circumstances.

2. The proposed operability and surveillance requirements are for the most part compatible with existing Technical Specification require-ments for the equipment involved (for example, as explained later, the battery surveillance requirements proposed exceed the recommen-dations of the draft Standard Technical Specification.

-3. The ability to take the plant from the "ho:" shutdown condition described above to the " cold" shutdown condition (temperature

<212'F) is required by Appendix R. Modifications have been per-formed, procedures have been prepared, and complete preoperational acccptance testing of the equipment needed to meet this requirement has been done.

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' Big Rock Point Plant. .8

. .TSCR - Alternate Shutdown-System f

14. This " cold" shutdown equipment, namely, alternate power sources for a shutdown cooling system pump, reactor coolant water pump, fuel pit

, pump, control rod drive booster pump, and a service water pump, provides very little added margin of safety in performing it's function. .This equipment is provided merely to lower the tempera-ture of the primary system from just above the boiling point to below the boiling point.

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5. The " cold" shutdown equipment listed does not currently have any ,

' operability requirements in the Big Rock Point Technical Specifications.

It would be inconsistent to add operability requirements for equip--

4- , ment that has very little importance to nuclear safety. In each '

case, if the equipment were to fail, the ability to maintain safe

" hot" shutdown (approximately 212*F) indefinitely is not affected.

therefore time would be available to repair any defective component.

, 6. -It would be beyond the requirements of Appendix R to assume that the

, emergency condenser.will fail at the time of the design basis fire -

-Appendix R does not require consideration of unrelated single failures concurrent with a fire and loss of offsite power. '

Based on these reasons, it is considered inconsistent and inappropriate to include operability requirements for listed " cold" shutdown equipment

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in,the Technical Specifications. However, to insure that equipment-needed to achieve and maintain " cold" shutdown is available, a surveil-lance requirement (4.7.13.3) was included in this proposal.

The control rod drive pump operability requirement is listed as sixty days, not seven days. This is due to the fact that an alternate method of makeup to the primary system is already available from the fire system by manually operating core spray valvs inside containment with a pressure of less than 110 psig. This alternative is included in the operating procedures for the alternate shutdown system and can be relied on during any time the pump itselfLis inoperable. (If the normal power supply were inoperable, but the pump itself was ready for service, the

-alternate shutdown method would still be considered operable.) This therefore follows the guidance of the draft Standard Technical Specifications. Note that under the conditions of loss of the ability j~~.

to open the core spray valves remotely from outside containment, with no other source of makeup available to the primary system the RDS system would be manually inhibited as long as the core spray system is inoperable.

,. -The-emergency condenser makeup line flow switch and low level alarm indicating lights are also listed with sixty day operability require- L ments. The loss of these indicating lights in no way affects the

' ability of the system to provide makeup to the shell of the emergency

, condenser. They provide information to assess the need for makeup and

! the actual makeup flow. Without either of these lights operable, the t

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. ec Big Rock' Point Plent 9

- TSCR - Alternate Shutdown System

-function can still' be performed by entering containment and checking the sight glass at the emergency condenser. It is also known that makeup is

. required within.four hours and that lack of makeup would cause the primary system to eventually repressurize, of which indication is 4 available. As these backup measures are available, it is appropriate to include'these items under the sixty day requirements.

The emergency condenser consists of two redundant loops. Existing Technical Specification 4.1.2(b) states that, should one emergency condenser tube bundle. develop a leak during power operation, it will be permissible to isolate the leaking tube bundle until the next outage.

It also requires.immediate' shutdown if both loops are inoperable. The proposed alternate shutdown section allows loss of one loop, consistent with 4.1.2(b), and requires shutdown in seven days for loss of alternate shutdown control of both loops. (Loss of normal control.of both loops would require immediate' shutdown per 4.1.2(b).) This makes the proposal consistent with existing and draft standard technical specifications.

A calibration surveillance is not included for the Emergency Co .4enser Make-up Line Flow Switch Indicating Light, FS-4947. The intent of this flow switch is to provide a positive indication that SV-4947 had ener-gized and that water flow has been established. It is not intended to have a calibrated-flow switch to provide a calibrated flow reading.

The alternate shutdown system battery was not put in Standard Technical Specification format as was Section 3/4.7.13. It replaces the station battery as the power source for the main steam isolation valve and

- emergency condenser outlet valves, and therefore requires more restric-tive requirements than those of Appendix R. The surveillance require-ments are consistent with the existing station battery requirements and

- with applicable IEEE Standards for Class 1E battery installations.

The battery is sized to allow several days following loss of the charger before it would no-longer be able to support the equipment operations required for alternate safe shutdown. Therefore the function of the charger is not critical to the Class 1E function of the battery and is

-not added to the Technical Specifications.

Note that the eight hour design time interval listed (to be consistent with station battery requirements) is in reality far exceeded during the actual service test. This test is designed to simulate the load profile that would exist under the Appendix R assumptions (minimum of nine days without a charger followed by seventy-two hours of alternate shutdown loads).' This twelve (12) day load profile is condensed into an equiva-lent eight-(8) hour load test. (In other words, a service test is not required by Ar 3adix R, but the eight (8) hour test that is done simulates t ' extensive Appendix R loads, exceeding both Class IE

. and Appendi tirements.)

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Big R ck Point Plant 10 TSCR - Alternate Shutdown System Additional fire detection requirements are proposed to the existing requirements in Section 3.3.3.8 of the technical specifications in order to cover the new Alternate Shutdown Building. This structure houses safety-related equipment required to operate the main steam isolation valve and emergency condenser outlet valves. This addition makes the new area consistent with technical specification requirements for all other safety-related areas of the plant.

The proposed change to the existing requirements in Specification 3/4.7.12 and bases adds active fire barriers (fire doors and dampers).

This change establishes surveillance and operability requirements which verify the active barriers are capable of performing their safety function.

III. Analysis of No Significant Hazards Considerations This change adds operability and surveillance requirements for equipmect required to operate to assure a safe method of cooling the primary system, in the event of a fire. This proposed change (and associated

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modifications as previously approved in NRC Safety Evaluations dated March 8, 1983 and March 26, 1985) decreases significantly the conse-quences of a design basis fire.

The alternate shutdown system battery replaces the station battery as the power source for the main steam isolation valve, and emergency condenser outlet valves. The design and operability requirements of this battery system are consistent with those of the station battery currently addressed by the Big Rock Point Technical Specifications, rnus not increasing the probability or consequences of an accident previcasly evaluated.

The proposed changes do not change the existing requirements for operability or surveillance of the shutdown system equipment except to place additional restrictions and surveillance requirements on such equipment. The changes do not allow the equipment to be operated in any new or different way from what is currently allowed and therefore do not create the possibility of a new or different kind of accident from any acciden previously evaluated.

Existing Technical Specification operability and surveillance require-ments have in no case been reduced by the proposed change. Only addi-tional operability and surveillance requirements are added for safe shutdown equipment, thus ne margins of safety will be reduced with issuance of this proposed change. Consequently, this proposed change does not involve a significant hazards consideration.

IV. Conclusion The Big Rock Point Plant Review Committee has reviewed this Technical Specification Change Request and has determined that this change does not involve an unreviewed safety question and therefore involves no TSB0985-0289-NLO4

Big Rock Point Plant 11 TSCR - Alternate Shutdown System significant hazards consideration. This. change has also been. reviewed under the. cognizance of the Nuclear Safety Board. A copy of this l Technical Specification Change Request has been sent to the State of Michigan official designated to receive such Amendments to the Operating License.

i. CONSUMERS POWER COMPANY 1

By.

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A F 'W Buckman, Vice Presis.e Nuclear Operations l-Sworn and subscribed to before me this 21st day of April 1986.

Elaine E Buehrer,. Notary Public h u/w Jackson County, Michigan

.My commission expires October 31, 1989 TSB0985-0289-NLO4

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