ML18052A135

Application for Amend to License DPR-20,consolidating Previous Submittals Re Auxiliary Feedwater Sys,Per TMI Action Item II.E.1.1 & Generic Ltr 83-37

ML18052A135
Person / Time
Site:	Palisades
Issue date:	10/28/1985
From:	BERRY K W CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML18052A134	List: ML18052A132 ML18052A135 ML18052A136
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.E.1.1, TASK-TM GL-83-37, NUDOCS 8511010059
Download: ML18052A135 (6)

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___ COMPANY -Docket 50-255 Request for Change to the Technical Specifications License DPR-20 For the reasons hereinafter set forth, it is requested that the Technical Specifications contained in the Provisional Operating License DPR-20, Docket 50-255, issued to Consumers Power Company on October 16, 1972, for the Palisades Plant be changed as described in Section I below: I. Changes Revised Technical Specifications pages are attached.

Proposed changes are shown by a vertical line in the right-hand margin. The following sections of the Technical Specifications are affected by these proposed changes: Section 3.3, Section 3.5.1 a -f, Section 3.5.2 a -e, Section 3.5.3, Section 3.5.4, Section 3.5, Section 3.17 -Table 3.17.4, Section 4.6.1.c, Section 4.9 and Section 4.1 -Table 4.1.3. The following is a brief description of each change: Specification 3.3 "Basis" -Change last sentence to reflect two rather than three high-pressure safety injection pumps. Specification 3.5.1.a -The existing Specification refers to the operability of both pumps implying the existence of only two pumps. As a result of the Auxiliary Feedwater System Modifications, the Plant will have three auxiliary feedwater pumps thus this specification now refers to the operability of all three pumps. Operability of the steam driven pump has been changed to reflect the fact that full flow conditions can not be established at 325°F. Specification 3.5.1.-b*-

This is a new Specification which makes Plant personnel aware of.Auxiliary Feedwater System instrumentation operability requirements which are not addressed in Specification 3.5 Specification 3.5.1.c is a new Specification which specifically defines the operability requirements of the Auxiliary Feedwater System flow control valves prior to heating the Plant. Specification 3.5.1.d -Same as existing Specification c except "are" is changed to "shall be". Specification 3_. 5 .1. e -Same_ as existing Specification b _except fire pump operability statement has been deleted since it is redundant with 3.5.1.a. Specification

3. 5 .1. f -Same as existing Specification

d. except "are" is changed to "shall be". 8511010059:

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• TSOP1085-0308-NL04

• I Specification 3.5.2 -Same as existing Specification 3.5.2 except the action statement has been changed to refer to new Specification 3.5.3. 2 ------------

.:.-This-is-a:-n.-ew-sp-ecTficatTongivrn:g-a Ilmitin_g

___ ----------condition of operation when auxiliary feedwater pump P-8A or P-8B is inoperable.

A period of 7 days is given to restore the affected pump to operability.

A period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is given to restore P-8C to operability.

Specification 3.5.2.b -This is a new Specification.

Permitting testing of the third AFW pump necessitates placing the controls of up to two other pumps in manual. Specification 3.5.2.c -This Specification is a revision to existing Specification 3.5.2.b. A period of 7 days was given to restore the alternate fire water suction. Specification 3.5.2.d -This is a new Specification giving a limiting condition of operation when alternate suction from the Service Water System to pump P-8C is not available.

A period of 7 days was given to restore the alternate service water suction. Specification 3.5.2.e -This is a new Specification giving a limiting condition of operation when one or two of the Auxiliary Feedwater System flow control valves is inoperable.

A period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is given to restore the flow control valves to operability.

Specification 3.5.3 -This is a new Specification which gives specific direction on what action to take if the requirements of 3.5.1 or the conditions of 3.5.2 cannot be met. Specification 3.5.4 -This Specification is almost identical to existing Specification 3.5.4, but it refers to all auxiliary feedwater pumps instead of both auxiliary feedwater pumps. Specification 3.5 Basis---This Section was revised to-give a more accurate description of the Auxiliary Feedwater System. Included in this basis document is a brief description of the pump start sequence.

Specification 3.17, Table 3.17.4, Item 13 -This is a r_evision to an existing Specification.

This Specification concerns the requirements for remote auxiliary feedwater flow indication available to operators.

It includes a new footnote (h) that specifies an action statement consistent with a given control valve. Specification 3.17, Table 3.17.4, Item 14 -This Specification concerns the of_ the

_Feedwater Actuation

_system Sens9r Channels which receive steam generator level signals and make a determination if they exceed specified setpoints.

Specification 3.17, Table 3.17.4, Item 15 -This Specification concerns the operability of the Auxiliary Feedwater Actuation System Actuation Channels which receive trip signals from the sensor channels and then generate the appropriate signal to the Auxiliary Feedwater System equipment.

TSOP1085-0308-NL04 Specification 3.17, Table 3.17.4, Item 16 -This is an existing Technical Specification numbered as Item 15 on Table 3.17.4. Specification 4.1, Table 4.1.3, Item 15.a --The monthly AFw-pump -check by comparison of channels of the flow indication is deleted. Existing item 15.b is change to item 15.a 3 Specification 4.1, Table 4.1.3, Item 16a -The channel description is changed from "Auto Initiation" to "Start" and the surveillance method is changed from "internal test signal" to "switch" to more*accurately reflect the actual surveillance test performed.

Specification 4.1, Table 4.1.3, NOTE 3 has been revised to state that the auxiliary feedwater pumps will be started from the control room hand switch, from the breaker (or alternate steam supply), and from the pump test -key switch in a three month period; this is a more accurate description of what is performed in the Surveillance Test. Specification 4.6.1.c -This specification revision deletes reference to HPSI pump P66C which is now referred to as auxiliary feedwater pump P-8C. Specification 4.9 -Specification a, b, and the Basis have been revised .to reflect the surveillance requirements of the Standard Technical Specifications consistent with format and concept within the constraints of the existing plant design and construction.

II. Discussion The above proposed Technical Specifications changes are requested.

Specification 3.3, "Basis" and Specification 4.6.1.c -In response to NUREG-0737 Action Item II. E.1.1, "Auxiliary Feedwater System Evaluation, Consumers Power Company proposed, in a letter dated November 2, 1981, to modify the existing Palisades Piant design. -Proposed Technical Specifications were submitted by letter dated August 29, 1983. The design modification adapted the existing spare high pressure safety injection (HPSI) pump, P-66C, for auxiliary feedwater service. This design modification has been accepted by the NRC (reference Amendment No 83 dated June 19, 1984), and Consumers Power Company completed this modification during the 1983-1984 refueling outage. The above proposed Technical Specifications change is requested to bring the Palisades Technical Specifications into conformance with the actual as-built plant design. Specification See Section I. Specification 3.5.1.b -See Section I. Specification 3.5.1.c -If the Plant is in cold shutdown and one of the flow control valves is malfunctioning, the valve should be repaired prior to heating the Plant to ensure total Auxiliary Feedwater System operability.

Specification 3.5.1.d,e,f

-See Section I. TSOP1085-0308-NL04

• 4 Specification 3.5.2.a -If P-8A or P-8B is inoperable, the Plant still has two independent and redundant auxiliary feedwater pumps complete with associated equipment to Supply <_l,UX_i_liary feedwater to the -steam generators.

However, if P-8A or P-8B is

.. the-reduncfancy the auxiliary feedwater system is reduced. Therefore, although inoperability of P-8A or P-8B is not a serious deficiency it is not advantageous for the Plant to have one of these pumps out of service as a normal Plant condition.

If P-8C is inoperable, the Plant still has one Auxiliary Feedwater System pipe train available to supply auxiliary

' feedwater to the steam generators.

The limiting condition of operation of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for pump P-8C is consistent with the Standard Technical Specifications.

Specification 3.5.2.b -See Section I Specification 3.5.2.c -The auxiliary feedwater system now has 2 secondary suction sources to the auxiliary feedwater pumps. The current Technical Specification 3.5.2.b has a limiting condition of operation time period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the alternate fire water suction to the auxiliary feedwater pumps P-8A and P-8B. With an additional independent secondary suction source to auxiliary feedwater pump P-8C, the time limit on the subject limiting condition of operation need not be as stringent.

Therefore, the time limit on the subject limiting condition of operation is extended to 7 days. Specification 3.5.2.d -A period of 7 days was selected to be consistent with Specification 3.5.2.c. The auxiliary feedwater system now has 2 secondary suction sources to the auxiliary feedwater pumps. The current Technical Specification 3.5.2.b has a limiting condition of operation time period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the alternate fire water suction to the auxiliary feedwater pumps P-8A and P-8B. With an additional independent secondary suction source to auxiliary feedwater pump P-8C, the time limit on the subject limiting condition of operation need not be as stringent.

Therefore, the time limit on the subject limiting condition of operation is extended to 7 days. Specification 3.5.2.e -One or two flow control valves may be inoperable, provided the Plant still has one Auxiliary Feedwater System pipe train available to supply auxiliary feedwater to the steam generators.

The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> limiting condition -of operation is consist.ent with that of pump P-8C. Specification 3.5.3 -See Section I. Specification 3.5.4 -See Section I. Specification 3.5.-Basis -See Section I. Specification 3.17, Table 3.17.4, Item 13 -In the Auxiliary Feedwater System, there are 2 remote flow indicators per flow control valve. It is necessary to have at least 1 remote flow indicator operable on each flow control valve for an operator to know how much water the auxiliary feedwater system is pumping to the steam generators and what steps he should take to adequately control auxiliary feedwater flow. New footnote (h) specifies an action statement consistent with a given flow control valve. TSOP1085-0308-NL04 Specification 3.17, Table 3.17.4, Item 14, -There are four Auxiliary Feedwater Actuation System Sensor Channels.

Two of the four sensor channels _must_ t:rip f9r the _Auxiliary Feedwater Actuation System actuation channels to trip. If 1-se-nsor-channel :ls inoperabie, the logic then is 2 out of 3 sensor channels must trip for the actuation channels to trip. If 2 sensor channels are inoperable, the logic is then 2 out of 2 sensor channels must trip for the actuation channels to trip. NOTE F states one of the Inoperable low level bistable modules (one for each steam generator) of an inoperable sensor channel must be in the tripped condition if two sensor channels are inoperable.

Thus, if two sensor channels are inoperable, the logic for the automatic pump start signal would be 1 out of 2. These conditions are very similar to what currently exists. Specification 3.17, Table 3.17.4, Item 16 -See Section I. Specification 4.9, -See Section I. Specification 4.1, Table 4.1.3, Item 15 and 16 -See Section I. Specification 4.1, Table 4.1.3, NOTE 3 -See Section I. Analysis of No Significant Hazards Consideration This change request results from a modification that utilized a spare high-pressure safety injection pump to provide a third auxiliary feedwater pump with its own independent auxiliary feedwater train to both steam generators.

In addition to the new auxiliary feedwater train, the system now has 2 secondary suction sources to the auxiliary feedwater pumps. The modification responded to Item II.E.1.1 of NUREG-0737, Long Term Auxiliary Feedwater System Evaluation.

The modification improves the reliability and performance of the auxiliary feedwater system. The requested specification changes reflect operability, action statements, surveillance requirements and basis for the new system. 5 They are consistent with the format and content requirements of the Standard Technical Specifications within the constraints of the existing plant design and construction.

The limiting conditions of operation (LCO) for the auxiliary feedwater pumps P-8A and P-8B however have been extended from 3 days to 7 days. The change request also reduces the existing flow testing of the system from monthly to quarterly in accordance with the ASME B&PV Code requirements.

The LCO extension and the reduction in flow testing from existing Technical Specification requirements are consistent with the improved reliability and performance of the auxiliary f eedwater system. Therefore this request does not involve an increase in the probability or consequences of previously evaluated accidents since system reliability has been improved.

Based on engineering judgment and the partially completed Probabilistic Risk Assessment for Palisades Plant, it is concluded that quarterly flow testing of the AFW system is optimum in establishing operability yet providing for a reduction in the cycling of the AFW inlet nozzles on the steam generators.

Furthermore, the design of the new nozzles incorporates the results of our analysis of the previous failed sparger thermal liner and external piping to assure a different or new type accident is not created. Therefore, this proposed change TSOP1085-0308-NL04

• request does not create the possibility of a new or different kind of accident from any accident previously evaluated.

6 The *changes proposed by-the re*quest invoJ:ve afi increase in the -1tlafgiri of safety as defined in the proposed Technical Specification Basis. The Auxiliary Feedwater System is designed so that an automatic start signal is generated to the auxiliary feedwater pumps upon low secondary side steam generator level. If pump P-8A fails to start or establish flow within a specified.period of time, pump P-8C receives an automatic start signal. If both pumps P-8A and P-8C fail to start or establish flow within each pump's specified period of time, auxiliary feedwater pump P-8B receives an automatic start signal. The previous margin of safety was established via the operation of only two pumps. The service water makeup to the auxiliary feedwater pump suction in addition to the firewater suction source also contributes to an increase in the margin of safety. Therefore, the change does not involve a significant hazards

• consideration.

III. Conclusion The Palisades 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 By, fif)/!JdJ/!JC R B DeWitt, Vice President Nuclear Operations Sw6rn and subscribed to before me this 28th day of October 1985. 1987. *' t. S. I\ ' TSOP1085-0308-NL04