ML18051B407

Application for Amend to License DPR-20,revising Tech Specs to Change Requirement to Flow Test Auxiliary Feedwater Pump Discharge Valves from Monthly Test During Plant Operations to Refueling Outage Test

ML18051B407
Person / Time
Site:	Palisades
Issue date:	05/31/1985
From:	Dewitt R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML18051B406	List: ML18051B405 ML18051B407 ML18051B408
References
NUDOCS 8506040180
Download: ML18051B407 (4)

Text

CONSUMERS POWER 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 Specification 4.9 Auxiliary Feed-Water System Replace existing Section 4.9 "Specifications" "a and b" with the following: "Specifications Demonstrate the operability of each feedwater pump: a. At least once per 31 days: 1. The operabi.lity of each motor-driven pump shall be confirmed as required by Specification 4.3.c and Table 4.1.3. Ttem 16a. b. 2. The operability of the steam driven pump shall be confirmed as required by Specification 4.3.c. and Table 4.1.3. Item 16a. The provisions of Specification 3.0.4 are not applicable for entry into Hot Standby. 3. Verifying that each non-automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.

At least once per 18 months by: 1. Verifying that each Automatic Valve (CV-0736A, CV-0737A, CV-0727 and CV-0749) actuates to its correct position (or that specified flow is established) upon receipt of a simulated auxiliary feedwater pump start.signal.

2. Verifying that each pump breaker (or steam valve control) receives an actuation signal upon receipt of an auxiliary feedwater actuation test signal." Specification 4.9 Basis Delete the existing Basis, Section 4.9 which specifies simultaneous testing of the auxiliary feedwater pumps with the discharge valves to confirm a flow path to the steam generator.

The new Basis will read as follows: r-8506040180 850531

• I l PDR ADOCK 05000255 P

• PDR *' '. -. -NU0385-0162C-NL04 TSCR-Palisades Plant 2 "Basis The periodic testing of Section 4.9.a. will verify auxiliary feedwater pump operability by recirculating water to the condensate storage tank and monitoring pump performance as specified in Section 4.3.c. The operability testing of Section 4.9.b. will verify auto initiation of the auxiliary feedwater system by simulating a low steam generator and observation of an actuation signal for the electric-driven pump breakers and for the steam-driven pump valve control. Operability of the flow control valves (CV-0736A, CV-0737A, CV-0727 and CV-0749) will be verified through simulation of an auxiliary feedwater pump start signal and observing valve actuation to its correct position or by auxiliary feedwater system flow as monitored by installed instrumentation." Specification Table 4.1.3 Delete from Table 4.1.3, item 15.a, .the monthly AFW Pump check by comparison of channels of the flow indication.

Change existing item "15b" to new item "15a". Change 16.a., Surveillance Method from "internal test signal" to "switch" as follows: Surveillance "Channel Description Function Frequency Surveillance Method 15. 16. II. Auxiliary Feed a. Calibrate R a *. Known Differential Pressure Pump Flow Applied to Sensors Indication Auxiliary Feed a. Test M (3) (5) a. Switch Pump Auto b. Calibrate R b. Known Differential Initiation Pressure Applied to Sensors Discussion The above proposed Technical Specifications changes are requested in order to reduce the occurrences of putting cold water into the steam generator during plant operation.

Since the AFW system draws make-up water from the condensate storage tank during the monthly operability test cold water which may be as low as 45 degrees Fahrenheit, imposes. considerable thermal loads on the AFW *steam generator nozzle and nozzle liner. The concern was discussed in a meeting with NRC on May 23, 1984 following our reporting of an event which occurred involving failures to our previous AFW nozzle and sparger. (Reference Licensee Event Report No.84-003 and IE Information Notice No. 84-32). Although the results of our analysis of the failed sparger thermal liner and external piping were incorporated into the design of our new nozzle to prohibit recurrence, good engineering practice necessitates that we reduce all unnecessary thermal loads to the AFW system. NU0385-0162C-NL04 TSCR-Palisades Plant A review of ASME B&PV Code Section XI and the Standard Technical Specifications did not produce any basis for the existing technical specification requirement to flow test the AFW pump discharge valves on a monthly interval.

The valves are specified by the Code as Category B valves and are stroke tested once every three months in accordance with the Code. The monthly operability test of the pumps will be accomplished through the use of an existing bypass to the condensate storage tank. This proposed change incorporates the surveillance requirements of NUREG-0212, the Standard Technical Specification.

Basis for Determination of No Significant Hazards Consideration 3 We have reviewed the proposed request to change the requirement to flow test the AFW pump discharge valves from a monthly t.est during plant operations to a refueling outage test in accordance with the requirements of. the ASME B&PV Code Section XI, NUREG-0737, and the guidance of Generic Letter 83-37 in order to determine whether or not this change involves a significant hazards consideration.

In our review, we have u.sed the guidance of cerfain '*examples (48FR14870).

One of the examples (vii) in guidance is if a change makes a license conform to changes in the regulation, where the license change results in very minor changes to facility operations clearly in keeping with the regulations then that change can be considered not likely to involve significant hazards considerations.

In another example (vi), the guidance identifies that a change may result in some increase to the probability or consequences of a previously analyzed accident or may reduce in some way a safety margin, but where the results of the change are clearly within all acceptable criteria with respect to the system or component specified in the Standard Review Plan then that change may also be considered not likely to involve significant hazards consideration.

Since this change does not result in an increase in the probability or consequences of a previously analyzed accident nor reduce a safety margin specified in the Palisades Technical Specifications and the Standard Review Plan (SRP) specifies that the Combustion Engineering Standard Technical Specification (STS), NUREG-0212, is consistent with regulatory guidance contained in the SRP, and this change is consistent with the STS, we have determined that this change falls within the examples and 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 NU0385-0162C-NL04 TSCR-Palisades Plant 4 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 R B DeWiit, Vice President Nuclear Operations Sworn and subscribed to before me this 31st day of May 1985. urfey, Nota County, Mic ig My commission expires November 5, 1986. SHERRY LYNN DURFEY Notary Public, Jackson County, Mich. My Commission Expires Nov. 5, 1986. NU0385-0162C-NL04