ML20059B766

Safety Evaluation Supporting Amend 133 to License DPR-20

ML20059B766
Person / Time
Site:	Palisades
Issue date:	08/21/1990
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20059B764	List: ML20059B760 ML20059B766
References
NUDOCS 9008300078
Download: ML20059B766 (3)

Text

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NUCLEAR REGULATORY COMMISSION o

5 WASHINGTON, D. C. 20666

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-1 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.133 TO PROVISIONAL OPERATING LICENSE NO. DPR-20 L

CONSUMER 3-POWER COMPANY PALISADES PLANT ve DOCKET NO. 50-2F; L

1.0 INTRODUCTION

3

)-

By letter dated August 2,1989, Consumers Power Company (TSs) appendej (thelicensee) requested an amendment to the Technical Specifications

- Provisional Operating License No. DPR-20 for the Palisades Plant. The l

proposed amendment would delete the requirement for a hydrostatic test at i

150 percent of design pressure on ti,e critical service water system headers every five years. Specifically Table 4.2.2 Minimum Frequencies.for EquipmentTests,wouldbemodifledthroughdeletionofItem10, Critical Headers Service Water System.

The effect of this change would be to reduce the hydrostatic test pressure requirement from 150 percent of design pressure to 125. percent and to reduce the hydrostatic test frequency from once each five years to once each ten years.

2.0 DISCUSSION

.The current Palisades Technical Specification Table 4.2.2, Item 10, requires the service water (SRW) system to be hydrottatically tested to 150 psig

.every five years. The-SRW system is an ASME Code Class 3 system. As such, it also falls-under the normal Section XI inservice testing requirements consisting _of a VT-2 walkdown inspection at normal o erating pressure once 1

each inspection period of 3-1/3 years, with one of t1e tests conducted at.

l 1.25 times system design pressure each inservice inspection interval of 10 i

years.

The Palisades SRW system piping design pressure is'100 psig with a normal operating pressure of 65 psig.

In order to comply with ASME Section XI requirements and their existing Technical Specifications, the licensee currenti; performs two hydrostatic tests at 150 psig and one VT-2 walkdown inspection at normal operating pressure during each inservice inspection interval of 10 years.

3.0 EVALUATION The licensee currently adheres to the ASME Code,Section XI, 1983 Edition with Addendum through Summer 1983.

Paragraph IWD-5223 of the Code requires a system hydrostatic test pressure of at host 1.25 times the ryttem pressure for systems with a design tem design temperature is 285'F.)perature above 200*F. (The Pal 19adas SRW system The system presure is requireo Lo be the 9008300078 900821 DR ADOCK 0500 5

~2-lowest pressure setting among the number of safety or relief valves provided for overpressure protection within the boundary of the system to be tested.

For systems not provideo with safety or relief valves, the code states that system design pressure shall be substituted for system pressure when calcula-ting the proper hydrostatic test pressure.

The SRW system does not contain any safety or relief valves (verified by a review of the SRW system piping and instrumentation drawing in the Final Safety Analysis Report and per discussion with the licensee). As such, the pressure) ydrostatic test proposed by the licensee (1.25 times system design 125 psig h is consistent with ASME inservice testing requirements.

The licensee perfr med design document reviews and correspondence searches in an attempt to &termine the basis for the existing TS requirement of.a 150 psig hydrost6 tic test every five years. A review of past changes to TS Table 4.2.2 reveals that this hydrostatic test was present when the licensee's custom TSs were originally approved and was not a testing requirement imposed by the staff at some later date. The existing TS was implemented prior to the evolution of the inservice testing requirements for Class 3 systems set forth in the applicable edition and addenda of ASME Code,Section XI pursuantto50.55a(g).

The existing TS also appears to have been chosen on the basis of engineering judgment.

The licensee states that since initial plant operation, no system piping deficiencies have been detected during the 150 psig testing. The staff agrees with the licensee that testing the SRW system to 150 psig is not necessary to determine system operability.

Hydrostatic testing in accordance with the ASME Code would be consistent with industry practice for Class 3-systems and Standard Technical Specifications. Although the hydrostatic test frequency is also being reduced (from once every five yerrs to once every inspection interval of.10 years), there are no operating or design-considerations which warrant a greater testing frequency.

In practice, the second hydrostatic test per 10 year inspection interval will be replaced by a VT-2 walkdown at normal system operating pressure,ble to the facility.as specified by the edition of the ASME Code,Section XI that is applica In summary, the licensee has been hydrostatically testing the SRW system at a slightly higher pressure and at a greater testing frequency than required by the ASME Code. There are no operational or design considerations which

' warrant the testing required by TS Table 4.2.2, hem 10. Hydrostatic testing -

of the SRW system will continue to be accomplished in accordance with the ASME Code,Section XI inservice testing requirements. Therefore, this proposed TS change is considered acceptable.

4.0 ENVIRONMENTAL CONSIDERATION

This amendment involves a change in the installation or use of a facility component -located within the restricted area as defined in 10 CFR Part 20 and a change in a surveillance requirement. We have determined that the amendment involves no significant increase in the amounts, and no significant l

3-change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.

The Comission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public coment on such finding. Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuantto10CFR51.22(b),noenvironmentalimpactstatement or environmental assessment need be prepared in connection with the issuance of this amendment.

5.0 CONCLUSION

. Wehaveconcluded,basedontheconsiderationsdiscussedabove,that(1)there is reasonable assurance that the health and safety of the public will not be i

endangered by operation in the proposed manner, and (2) such activities will I

L be conducted in complianca with the Comission's regulations, and the issuance L

of the amendment will not be inimical to the common defense and security or to

).

the health and safety of the public.

l Date:

August 21, 199C

-Principal Contributor:

B. Holian i

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h August 21, 1990 l

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Docket No; 50-255 DISTRIBUTl.0F Docket Files JZwolin's ki NRC & Local PDRs GHill(4)

Mr. Gerald B.~ Slade PD31 R/F-Wanda' Jones Plant Ceritral Manager JCalvo SMeadct Palisades Plant ACRS (10)

EJordan 27780 Blue Star. Memorial Highway BHolian' GPA/PA Covert, Michigan 49043 OGC' ARM /LFMB DHagan-

SUBJECT:

AMENDMENT NO.133 TO PROVISIONAL OPERATIllG LICENSE NO. DPR-20:

FORTHEPALISADESPLANT(TACNO.73598)'

The Corraission has issued the enclosed Amendment flo.133 to Provisional Operating License No. DPR-20 for the Palisades Plant. This amendment ccnsists of changes to the Technical Specifications in responso to your erplicaticn dated August 2, 1989.

' This aniendnent dels.tes the requirement for a hydrostatic test at 150-percent of design every five years. pressure on the criticel service water system headers Systeni testing will continue under ASME,Section XI insttvice inspection requirenents.

~A-copy of our related Safety Evaluetion is also enclosed.

Notice of Issnance-vill be incit.ded in the Ccneiission's biweekly Federal Register riotice.-

Sincerely,

%d signw oy Crian E. Holieri, Project Manager

. Project Directcrate III-1 Divisien of Reactor Projects - III, IV, V and Special Projects Encicsures:

l1.

An:encn.ent No.133 to Littnse No. DPR-20 2.

Safety Evaluation cc w/ enclosures:

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.M. I. Miller', Esquire.

Nuclear Facilities and'

-Sidley & Austin.

Environmental Monitoring 54th Floor Section Office.

One First Ilhticrial Plaza

. Division of Radiologic 61, Chicagc, Illinois 60603 Health Mr.-Thomis A. McNish, Secretary

.P.O.. Box 30035 Consurrers Powtr Ccepany Lansing, Michigan 48909 t

212 West Michigbn Avenue Gerald Chernoff, P.C.

- Jacksor.,i Michigan 49201 Shaw, Pittman, Potts & Trowbridge Judd L. Bacon, Esquire 2500 H.-Street, N.W.

Ccrsurvr5-Pchtr Ccepany-Washington, D.C.

20037

- 212 Kest Michigan Avenue-

Jackson, Michigan 49201 Mr. David L._Brannen V. ice President-P.egional Ac' tit.istrator, Region III P611sades Generatir.g Plant

.U.S. Nucleer Regulatory Cormission c/o Bechtel Power Corporation 799 Recsevelt Road 15740 Shady Grove Rcad

_Gict. E11yr.,111ir cis 60137.

Gaithersburg, Maryland 20877

-Jerry Sarno iTcwr. ship.Sgtrvisor Ccvert. Township 3(197 l'-140 Highway Ccie r t, liithiger a9043

" Office.of the Governor Roon 1 - Capitc1 Evilding-Lansins, Fichigan 46913 Mr. 06sie J. Vandewalle Directoi, Safety and Licensing Pslisedts Flant 27780 Blue Star Men:orial HNy.

. Ccs ert, l'ichigen 49043 Resider.t Inspector c/o U.S.~l!cclear Regulatory Connission L

Palisades Plant 27762 Blue Star Mercrial Hwy.

Covert, Michigan 49043

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CONSUMERS POWER COMPANY q

PALISADES PLAN _T DOCKET _NO. 50-255 s

AMENDMENT TO P.00 VISIONAL OPE:!ATING LICENSE t

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- Amendment No.133 c

License No. DPR-20 1.

.The Kuclear Regulatory Cons.ission (the.C6sunission) has found that:

.A.

The application for amendinent by Consumers Power Company (the licensee) dated August 2,1989,' coir. plies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Cormission's rules and regulations set:forth in-10 CFR Chapter I; L

E.

The facility will operate -in conf ormity with the application,-

L the provisions of the Act, and the rules and regulations of the

(

Commissior.;

1 C.

There is reasonable assurance (i) that the activities authorized l-by this anendo.ent can be conducted without endangering th'e health and safety of the public; and (ii) that such activities will be l-conducted in compliar.ce with the Conmission's regulations; 3

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D.

The -issuance of this snendnent will.ct b'e inimical to the conaon

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defense and security or to the health and= safety of the public; and

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E.

The' issuance of this anendu.ent is in accordance with 10 CFR Part 51-of the Conrission's regulations and all applicable requirernents have been satisfied.

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2 Accordingly, the license is anended by changes to the Technical 2.

Specifications as indicated in the attachinent to this license acendrent and Paragraph 3.B. of-Provisional Operating License Hoi DPR-20 is hereby. amended to read as follows:

Technical Sp.e.c,1fications The Technical Spt-cific6tions contained in Appendices A and B, as revised through Amendirent No.133, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3.

This license ainendment is effective as of the date of its issuance and still be implernented nct later than August 29, 1990.-

FOR THE NUCLEAR REGULATORY-COMMISSION

(.

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Robert C. Pierson, Director-Project Directorate 111-1 Divisico of Reactor Projects - III, IV,.V and Special Projects Attachn ent:

Chuges to the Technical S cifications Cate of Issuerce: August 21, 1990

1 ATTACHEENT-TO LICEN5E, Apfpp3fy,Npd3J j

5 PROVISIONAL OPERATING LICENSE N.O. DPR-20 DOCKET NO. 50-255 Revise Appendix-A Technical Specifications by removing the pages identified telow and inserting the attached pages. The revised pages are identified by the (eptioned antendrent number and contain marginal lines indicating the area cf change.

REMOVE INSERT 4-15 4-15

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t-Table 4.2.2

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c Minimum Frequencies for Equipment Tests l

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P FSAR S6ction.

Test Frequency Reference i

It Control Rods

. Drop Times of All Full--

Each Re-7.4.1.3 Length Rods fueling i

Shutdown-C

-2.

Control Rods-Partial iovement of All Every Two 7. 4.1'. 3 Rods'(Mtnimum of 6 In)

Weeks t'

t-3..-Pressurizer Safety Set l'oint One Each 7.3.7 Valves Refueling Shutdown 4

Main Steam-Safety Set Point Five Each 4.3.4 Valves Refueling a

Shutdown-(=,-

s 5.

Refueling System Functioning Prior-to 9.11.3' Interlocks Refueling L

- Operat' ions --

j l

6.

Service Water System Functioning Each Re-9.1.2 Valve Actuation' fueling (SIS-CHP)

_ Operation 7.

Fire Protection Functioning Monthly 9.6.2 ll Pumps and Power l-1 Supply i

8.

Primary System Evaluate -

Daily 4

Leakage Amend 15, Ques 4.3.7-9.

Diesel Fuel Supply Fuel Inventory Daily 8.4.1

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10.

(Deleted

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I 4-15 Amendment No 12, 8I, 133 J

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NUCLEAR REGULATORY COMMISSION

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l SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION 4

RELATED TO AMENDMENT NO.133 TO PROVISIONAL OPERATING LICENSE NO. DPR-20 l

CONSUMERS POWER' COMPANY

[

PALISADES PLANT DOCKET NO. 50-255 4

1.0- INTRODUCTION By'1etter-dated August 2,1989, Consumers Power Company (the licensee) e requested an amendment to the.. Technical Specifications (TSs) appended to Provisional Operating License No. DPR-20 for the Palisades Plant. The proposed amendment would delete the requirement for a hydrostatic test at 4

l 150.- percent of design: pressure on the critical service water system headers-every five years.. - S e:1fically Table 4.2.2, Minimum Frequencies for EquipmentTests,woudbemodifIedthroughdeletionofItem10, Critical 3

Headers Service Water System. The effect of this change would be to reduce J

the hydroscatic test pressure requirement from 150 percent of design pressure l(

to 125 percent and to reduce the hydrostatic test frequency from once each five years to once each ten years.

2.0 DIS'CUSSION f

l The current Palisades Technical Specification Table 4.2.2, Item 10, requires i

the service water (SRW) system to be hydrostatically tested'to 150 psig every five years.

The.SRW system is an ASME Code Class 3-system. As such, it also falls under the normal Section XI inservice testing requirements consisting of a VT-2 walkdown-inspection at normal-o)erating pressure once each inspection period of 3-1/3 years,'with one of t1e tests conducted at 1.25 times system design pressura each inservice inspection interval-of 10 -

years, q

The Palisades SRW system piping design pressure-is 100 psig with a-normal-operating pressure of 65 psig.

In order to comply with ASME Section XI requirements and their existing Technical Specifications, the licensee t

-currently performs two hydrostatic tests at 150 psig and one VT-2 walkdown

' inspection at normal operating pressure during each inservice inspection interval of 10 years.

. 3.0 EVALUATION The licensee currently adheres to the ASME Code,Section XI,1983 Edition with Addendum through Summer 1983.

Paragraph IWD-5223 of the Code requires a system hydrostatic test pressure of at least 1.25 times the system pressure for systems with a design tem design temperature is 285'F.)perature above 200*F.

(The Palisades SRW system The system pressure is required to be the

I lowest pressure setting among the number of safety or relief valves provided for overpressure protection within the boundary of the system to be tested.

For systems not provided with safety or relief valves, the code states that system design pressure shall be substitutad for system pressure when calcula-ting the proper hydrostatic test pressure.

The SRW system does not contain any safety or relief valves (verified by a review of the SRW system piping and instrumentation drawing in the Final Safety Analysis Report and per discussion with the licensee). As such, the pressure) ydrostatic test proposed by the licensee (1.25 times system design 125 psig h is consistent with ASME inservice testing requirements.

The licensee performed design document reviews and correspondence searches in an attempt to detern:ine the basis for the existing TS requirement of a 150 psig hydrostatic telt every five years. A review of past changes to TS Table 4.2.2 reveals that this hydrostatic test was present when the licensee's y

custom TSs were origine11y approved and was not a testing requirement imposed by the staff at some later date. The existing TS was implemented prior to the evolution of the inservice testing requirements for Class 3 systems set forth in the applicable edition and addenda of ASME Code,Section XI pursuantto50.55a(g).

The existing TS also appears to have been chosen on the basis of engineering judgment.

The licensee states that since initial plant operation, no system piping t

deficiencies have been detected during the 150 psig testing. The staff agrees with the licensee that testing the SRW system to 150 psig is not necessary to determine system operability.

Hydrostatic testing in accordance i

with the ASME Code would be consistent with industry practice for Class 3 A

systems and Standard Technical Specifications. Although the hydrostatic test frequency is also being reduced (from once every_ five years to once every inspection interval of 10 years), there are no operating or design considerations which warrant a greater testing frequency.

In practice, the second hydrostatic test per 10 year inspection interval will be replaced by a VT-2 walkdown at normal system operating pressure, as specified by the edition of the ASME Code,Section XI that is applicable to the facility.

In summary, the licensee has been hydrostatically testing the SRW system at a slightly hyher pressure and at a greater testing frequency than required by the ASME Code. There are no operational or design considerations which warrant the testing required by TS Table 4.2.2, Item 10.

Hydrostatic testing of the SRW system will continue to be accomplished in accordance with the ASME Code,Section XI inservice testing requirements. Therefore, this proposed TS change is considered acceptable, 4c0 ENVIRONMENTAL CONSIDERATION This amendment involves a change in the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and a change in a surveillance requirement. We nave determined thet the amendment involves no significant increasa in the amounts, and no significant

^^

a[.

3-

. change in the types, of any. effluents that rey be released offsite, and that I

l there is no significant. increase in individual or cumulative occupational.

l radiation exposure. The Commission has previously issued a proposed finding L

that this amendmentLinvolves no significant-hazards consideration and there L

.has been no public comment on such finding. Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental im)act statement i

L or environmental assessment need be prepared in connection wit) the issuance of this amendment.

5.0 CONCLUSION

i We have concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations, and the issuance-of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Date:

August 21, 1990 Principal Contributor:

B. Holian l

3

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