ML20210E514
| ML20210E514 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 12/17/1986 |
| From: | Buckman F CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML20210E446 | List: |
| References | |
| NUDOCS 8702100317 | |
| Download: ML20210E514 (11) | |
Text
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e CONSUMERS POWER COMPANY Docket 50-155 Request for Change to the Technical Specifications License DPR-6 For the reasons hereinafter set forth, it is requested that the Technical 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:
"12.0 Fire Protection Program........................
150-157d (Section 3.3.3.8/4.3.3.8) Fire Detection Instrumentation..............l~.............
150-151 (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 Spray / Sprinkler Systems....................
154 (Section 3.7.11.5/4.7.11.5) Fire Hose Stations...................................
155 (Section 3.7.12/4.7.12) Penetration Fire Barriers...................................
156 (Section 3.7.13/4.7.13) Alternate Shutdown System............................
157-157b i
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 46 kV line, one diesel generater 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 8702100317 870206 all conditions except during cold shutdown.
If D
ADOCK0500ggS the station battery or the alternate shutdown p
battery is inoperable, no actions shall be taken which result in a reactivity addition, except cooldown, or which might result in the primary TSB0985-0289-NLO4
Big Rock Point Plant 2
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TSCR - Alternate Shutdown System coolant system being drained. The alternate shutdown battery may be inoperable during refuel-ing or shutdown operations as long as containment integrity for the main steam line is established."
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 seventy-two 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 battc..es corrected to 77'F, is 21.2.
(c)
Verify the station battery pilot cell voltage is 22.0 volts, the RDS b:Lcery pilot cell voltage is 26.0 volts and the alternate shutdown battery pilot cell voltage is 22.1 volts.
TSB0985-0289-NLO4
6 Big Rock Point Plant 3
TSCR. Alternate Shutdown System (d)
Verify the overall battery voltage is 2125 volts for the station battery, the RDS batter-ies and the alternate shutdown battery."
"A.
5 Sixty Months - At least once per 60 months during-shutdown, verify that the RDS batteries, the alternate shutdown battery and the station battery capacity are at least 80% of the manufac-turer's rating when subjected to a performance, discharge test. This performance discharge test shall be performed subsequent to the satisfactory completion of the required battery service test of Part 11.4.5.3.A.1.(h)."
1 C.
Bases for Section 11.3.5.3 and 11.4.5.3 Add the following:
"The alternate shutdown battery supplies power to the main steam isolation valve, the emergency condenser outlet valves and other alternate shutdown equipment. The battery is sized so that loss of the charger does not affect operability of the battery for up to six (6) days at a minimum of 25*F (nine (9) dayo at minimum of 40*F)."
D.
Section 3.3.3.8 Add to Table 3.3-8, the smoke detection instruments for the Alternate Shutdown Building, as follows:
1" "13.
Alternate Shutdown Building 2
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 l
Add the following specifications for the alternate shutdown system:
TSB0985-0289-NLO4
b Big Rock Point Plant 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 With less than the minimum ASD equipment in Table 3.3-9 OPERABLE, restore the inoperable equipment to OPERABLE within 7 days, or provide equivalent shutdown capability and restore the inoperable equipment to OPERABLE within 60 days, or 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 />.*
- The #1 control rod drive pump, its associated ASD power source and the two emergency condenser indicating lights are the ASD equipment considered to have equivalent shutdown capability.
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 switch, 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 ensure that equipment (alternate power sources) needed to achieve and maintain cold shutdown is available.
4.7.13.4 The ASD battery charger shall be demonstrated OPERABLE by performing a weekly verification that the float voltage is greater than 130 volts.
4.7.13.5 The ASD battery surveillance requirements are contained in Section 11.4.5.3.
- But no less than once every 18 months."
TSB0985-0289-NLO4
~,.
-Big Rock Point Plant 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 D um 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 M0-7053*
Starter OR Emergency Condenser Outlet Valve ASD MO-7063 Motor Control MO-7063*
Starter 2.
Main Steam Isolation Valve Control MO-7050 Motor M0-7050 Starter 3.
Emergency Condenser Firewater Makeup Panel C31 Valve Control SV-4947 4.
Control Rod Drive Pump No. 1 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 M0-7063, are inoperable at the same time.
NOTE: Alternate Shutdown Battery operability requirements are contained in Section 11.3.5.3."
TSB0985-0289-NLO4
Big Rock Point-Plant 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 Weekly compare to known level LI-6819 B. Calibration Every 18 apply known differential months pressures to transmitters
- 2. Steam Drum Pressure, A. Check Weekly compare to known pressure PI-6819 B. Calibration Every 18 apply known pressures to months transmitter
- 3. Emergency Condenser A. Check Monthly initiate flow in line Makeup Line Flow Switch Indicating Light.
FS-4947
- 4. Emergency Condenser Low A. Check Monthly simulate low level Level Alarm Indicating Light, LS-3550 B. Calibration Every 18 apply known differential (Panel C31) months pressure to switch" 1
TSB0985-0289-NLO4
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 Technical Specification operability and surveillance requirements for components of the alternate shutdown system installed in accordance with Appendix R to 10 CFR 50 as required by Item 8(j) of Generic Letter 81-12.
System design was reviewed and appcoved as discussed in the NRC Safety Evaluations dated March 8, 1983 and March 26, 1985. The added 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.
The 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 indefinitely 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 " hot" 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 TSB0985-0289-NLO4 k
Big Rock Point Plant-
-8 TSCR - Alternate Shutdown System acceptance testing of the equipment needed to meet this requirement has been done.
4.
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.
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-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 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 il control rod drive pump and its associated ASD power source are considered to have equivalent shutdown capability. 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 valves inside containment with a pressure of less than 110 psig. This alterna-tive is included in the operating procedures for the alternate shutdown system and can be relied on during any time the pump itself is inoper-able.
(If the normal power supply were inoperable, but'the pump itself was ready for service, the alternate shutdown method would still be considered operable.) Therefore, this follows the guidance of the draft Standard Technical Specifications. Note that under the conditions of loss of the ability to open the core spray valves remotely from outside containment, with no other source of makeup available to the primary i
system the RDS system would be manually inhibited as long as the core l
spray system is inoperable.
i.
The emergency condenser makeup line flow switch and low level alarm indicating lights are also considered to have equivalent shutdown capability. The loss of these indicating lights in no way affects the i
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 f
TSB0985-0289-NLO4 1
Big Rock Point Plant 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 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 available. As these backup measures are available, it is appropriate to consider these items to have equivalent shutdown capability.
The emergency condenser consists of two redundant loops. Existing i
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 Condenser 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 operability requirement for the alternate shutdown battery allows it to be inoperable during refueling or shutdown operation as long as contain-ment integrity for the main steam line is established.
In addition to the MS1V, the battery powers the emergency condenser outlet valves and fire water makeup valve, steam drum level and pressure instruments and alarms. Other than the MSIV, this equipment is required to be operable only during power operation. Either the MSIV or other means of isolat-ing the main steam line is required for containment integrity during refueling and shutdown, but as long as this function is fulfilled, the battery may be inoperable.
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 other than weekly verification of float voltage.
TSB0985-0289-NLO4
Big Rock Point Plant 10 TSCR - Alternate Shutdown System Note that the seventy-two hour design time interval listed 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 assump-tions (seventy-two hours of alternate shutdown loads without offsite power). It is also assumed that the battery has run without a battery charger for nine days preceding the seventy-two hours. This twelve-day load profile is condensed into an equivalent eight-hour load test.
(In other words, a service test is not required by Appendix R, but the eight-hour test that is done simulates the more extensive Appendix R loads, exceeding both Class 1E and Appendix R requirements.)
Additional fire detection requirements are proposed to the existing requirements in Section 3.3.3.8 of the Technical Specifications 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.
The surveillance interval for items 3A and 4A of Table 4.3-9 are listed as " monthly" in lieu of " weekly" as items IA and 2A for the following reasons:
1.
Both test procedures for functionally testing the flow switch and indicating light require manual valve manipulations which remove the emergency condenser level control scheme and fire water make-up source from service. Weekly testing of those devices creates a high unavailability of these components to perform their safety functions during power operation.
2.
As discussed in the last paragraph on page 8, without either light operable, the assessment functions can still be performed as described.
III. Analysis of No Significant Hazards Considerations This change adds operability and surveillance requirements for equipment required to operate to assure a safe method of cooling the primary system in the event of a fire. This proposed change (and associated 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, thus TSB0985-0289-NLO4
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Big Rock Point Plant 11
_TSCR - Alternate Shutdown System
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not increasing the probability or consequences of an accident previously evaluated.
The proposed changes do not change the existing requirements for opera-bility 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 de not create the possibility of a new or different kind of accident from any accident 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 no 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 significant hazards consideration. This change has also been reviewed under the cognizance of the Nuclear Safety Board. A copy of this Technical Specification Change Request has been sent to the State of Michigan official designated to receive such Amendments to the Operating License.
CONSUMERS POWER COMPANY f
~'}7 p'
5y
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F W Buckman', Vice PresilfEnt>
i Nuclear Operations Sworn and subscribed to before me this 17th day of December, 1986.
Elaine E Buehrer,' Notary Public Jackson County, Michigan My commission expires October 31, 1989 TSB0985-0289-NLO4
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