ML20215F994

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Application for Amend to License DPR-6,changing Tech Specs to Add Operability & Surveillance Requirements for Alternate Shutdown Sys Installed Per 10CFR50,App R & Generic Ltr 81-12.Request Supersedes 860421 Application
ML20215F994
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 12/17/1986
From: Berry K
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Office of Nuclear Reactor Regulation
Shared Package
ML20215F996 List:
References
GL-81-12, NUDOCS 8612240179
Download: ML20215F994 (12)
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@ym AIEMAW5 PROGRE55 Consumers Power Kenneth W Berry Director Nuclear Licensing General Ot'eces: 1945 West Parnell Road, Jackson, MI 49201 . (517) 788 1636 Cecember 17, 1986 Director, liuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

TECHNICAL SPECIFICATION CHANGE REQUEST - ALTERNATE SHUTDOWN SYSTEM Attached are three (3) originals and thirty-seven (37) conformed copies of a request for change to the Big Rock Point Technical Specifications. This change request supersedes our change request dated April 21, 1986. The change request is being resubmitted to resolve concerns raised during NRC staff review of our previous submittals.

These proposed changes add technical specification operability and surveillance requirements for the alternate shutdown system installed in accordance with Apperdix R to 10CFR50 as required by Item 8(j) of Generic Letter 81-12. This change request also includes proposed technical specifications for the active fire barriers and the fire detection instrumentation for the new Auxiliary Shutdown Building.

Pursuant to 10CFR170.12(c) a check in the amount of $150.00 was attached to our September 30, 1985 submittal, hence no fee is remitted with the submittel.

(,,-

Kenneth W Berry m

  • ~ }h P Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point Attachment __

8612240179 861217 00 PDR ADOCK 05000155 b

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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 contaired 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:

l 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 ............................ 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 Bases .......................................... 157c-157d f

B. Section 11.3.5.3 and 11.4.5.3 Add the Alternate Shutdown Battery System to the specificaticn 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 generator system, one statica 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 the station battery or the alternate shutdown battery is inoperable, no actions shall be taken which result in a reactivity addition, except cooldown, or which might result in the primary coolant system being drained."

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Big Rock Point Plant 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.

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"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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Big Rock Point Plant 3 TSCR - Alternate Shutdown System "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 is 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.I.(h)."

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 such 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) days 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:

"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 i' Add the following specifications for the alternate shutdown system:

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Big Rock Point Plant 4 TSCR - Alternate Shutdown System

" PLANT SYSTEMS a 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 ccmponent 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.

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.

j 4.7.13.5 The ASD battery surveillance requirements are contained i in Section 11.4.5.3.

  • But no less than once every 18 months."

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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 Drum Pressure /PI-6819 Panel C31
3. Emergency Condenser Low Level Panel C31 Alarm Indicating Light /LS-3550
4. Emergency Condenser Firewster 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 M0-7063* 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. I and Equipment Lock associated ASD Power Source
  • Section 3.7.13(a) applies only if the alt'ernate shutdown controls for both emergency condenser outlet valves, M0-7053 and M0-7063, are inoperable at the same time.

j NOTE: Alternate Shutdown Battery operability requirements are contained in Section 11.3.5.3."

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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" TSB0985-0289-NLO4 L >

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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. i 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 approved 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 make,up to the primary system. At Big Rock this condition is very stable. The reactor can be maintained in safe i 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 acceptance testing of the equipment needed to meet this requirement he.s been done.

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r ~3 Big Rock Point Plant 8 TSCR - Alternate Shutdown System

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, thereforr: 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 #1 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 alternative is included in the operating procedures fer the alts:nate shutdown system and can be relied on during any time C.e pump itself is 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 i of loss of the ability to open the core spray valves remotely from I

outside containment, with no other source of makeup available to the primary systen 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 considered to have equivalent shutdown capability. 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 function can still be performed by entering containment and checking the sight glass at the emergency condenser. It is also known that makeup is TSB0985-0289-NLO4

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Big Rock Point Plant 9 TSCR - Alternate Shutdown System 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 squivalent shutdown capability.

The ensrgency 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 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 battery is sized to allow several days following loss of the charger before it would nc 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.

Note that the eight 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 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 equivalent eight (8) hour load test.

(In other words, a service test is not required by Appendix R, but the eight (8) hour test that is done simulates the more extensive Appendix R loads, exceeding both Class IE and Appendix R requirements.)

Additional fire detection requirements are proposed to the existing requirements in Section 3.3.3.8 of the technical specifications in ordec TSB0985-0289-NLO4 L

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e Big Rock Point Plant 10 TSCR - Alternate Shutdown System

.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 within.

III. Analysis of No Significant Hazards Considerations This change adds operability and surveillance requirements for equipment I

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 appreved in NRC Safety Evaluations dated March 8, 1983 and March 26, 1985) decreases significantly the conse-i 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 not increasing the probability or consequences of an accident previously 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 l accident previously evaluated.

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Big Rock Point Plant 11 TSCR - Alternate Shutdown System 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 15y 7/

/u <d F V Buckman, Vice PresTaent Nuclear Operations Sworn and subscribed to before me this 17th day of December, 1986.

M Elaine E Buehrer, Notary Public

.Tackson County, Michigan My commission expires October 31, 1989 l

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