ML18054A621
| ML18054A621 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/31/1988 |
| From: | Johnson B CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8904110030 | |
| Download: ML18054A621 (40) | |
Text
General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-0550 March 31, 1989 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
1988 A11NUAL REPORT OF FACILITY CHANGES, TESTS AND EXPERIMENTS Attached is Consumers Power Company's Annual Report describing the Facility Changes (FC), Specification Changes (SC), tests and experiments initiated in 1988 and declared operable the Palisades Plant during 1988 or first quarter of 1989 in the first attachment and those initiated in 1988 but not declared operable or closed out in the second attachment.
Included in the first attachment are FC's 587, 680, 756, 758, 760-04 and SC's86-162, 87-148,87-156, 87-344 and 87-375 which were closed in 1988 but were not included in the reports for the year in which they were initiated.
This report is submitted in accordance with the provisions of 10CFR50.59(b).
Brian D Johnson Staff Licensing Engineer CC Administrator, Region III, NRC NRC Resident Inspector - Palisades Attachment OC0389-0109-NL02 g- /otf/ 100 36 A CMS ENERGY COMPANY
OC0389-0109-NL02 ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 PALISADES PLANT ANNUAL REPORT TO THE NRC FOR 50.59 REVIEWS March 31, 1989 38 Pages
FACILITY CHANGES, SPECIFICATION CHANGES, TESTS AND EXPERIMENTS INITIATED IN 1988*
DECLARED OPERABLE IN 1988 FINAL CLOSEOUT IN 1988 OR IN THE FIRST QUARTER OF 1989
~
FC-567 This modification covers the installation of an instrumentation system for detection of inadequate Reactor Core cooling.
The modification consists of:
- 1.
Expanding the range and monitoring capability of the subcooled margin monitor.
- 2.
Replacement of the (16) existing core thermocouples with ones environ-men~ally qualified, arid
- 3. Installation of a new reactor vessel level monitoring system.
SAFETY ANALYSIS
SUMMARY
PHASE 1 This modification provides new pressurizer pressure and primary coolant temp-erature transmitters as inputs to the subcooled margin monitor (SHH) to expand the range of the SMM below the present lower limit of 515°F.
Addition-ally, the in-containment electrical connectors and cabling of 16 incore thermo-couples are being upgraded to meet environmental qualification.
This facility change modifies equipment and components currently described in the FSAR to provide instrumentation having increased reliability.
The probability of concurrence or the malfunction of equipment important to safety previously evaluated in the FSAR is.not increased.
The increased range of the SHH and the upgrade of the incore thermocouples increases the reliability of instrumenta-tion used by the control room operators during post accident conditions and thus potentially reduces the conseq~ences of an accident.
This modification utilized equipment and components currently described in the FSAR*
Replacement components and equipment are qualified in accordance with applicable requirem~nts of IEEE standards. Thus the possibility of an accident or malfunction of a type not previously identified in the FSAR is not created.
The margin of safety as defined in the basis for any technical specification is not reduced.
The subcooled margin monitor is currently included in technical specifications.
The 16 upgraded incore thermocouples will be included in technical specifications following completion of the modification *
. PHASE II This phase provided redundant instruments to monitor reactor vessel level from near the top of the head to near the top of the fuel *. The instruments are.
inserted into existing incore detector guide tubes through existing instrument flanges mounted on the reactor head.
Cabling exits the reactor vessel through seal plugs having a design similar to the incore instrument seal plugs.
As the reactor vessel level monitoring system is similar to the incore detectors presently described in the FSAR, the probability of occurrence or malfunction of equipment important to safety previously evaluated in the FSAR is not MI0189-018A-TC07 2
increased.
The reactor vessel level information provided to the control room operators aids in their decision making process during post accident conditions and thus potentially reduces the consequences of an accident.
The reactor vessel level monitoring system is similar to the design of the existing incore detector system. *The components and equipment are qualified in accordance with applicable requirements of IEEE standards.
Thus the possibil-ity of an accident or malfunction of a different type not previously identified in the FSAR is not created.
The reactor vessel level monitoring system will be included in the technical specification following completion of this modification.
FC-680 This Facility Change involved the rerack of the Spent Fuel Pool, covering the storing of intact fuel assemblies.
New Westinghouse racks have replaced approximately one half of the NUS racks. The cask anti-tip frame was modified by removing the seismic restraints which were required by the NUS racks, but not required by the Westinghouse racks.
The Westinghouse racks are higher density, increasing fuel storage storage capacity from 798 locations to 892 usable lo~ations.
SAFETY ANALYSIS
SUMMARY
An analysis was compl~ted by Westinghouse and reviewed by CPCO describing the interface between the existing NUS racks and the new Westinghouse racks which shows that the interface between the two types of racks are acceptable for use in the Palisades Spent Fuel Pool without modification to existing NUS racks.
The actual installation of the new racks was completed by following an Instal-lation Procedure which was reviewed and approved in accordance with our Admin-istrative Procedures.
To minimize personnel exposure, initial rack decontamin-ation was completed within the Spent Fuel Pool, under water, using high pres-sure spray.
Effects of the high pressure water spray on spent fuel and remain-ing racks are very unlikely due to the equipment arrangement.
This procedure had been completed by Westinghouse at Turkey Point Nuclear Plant without adversely affecting the fuel pool or spent fuel.
The probability of an occurrence or the consequences of an accident or mal-function of equipment important to safety previously evaluated in the FSAR is not increased by this modification.
The possibility of an accident or mal-function of a different type than previously evaluated in the FSAR is not created. This modification does.not reduce the margin of safety as defined in the basis of any technical specification. A technical specification change was part of a Licensing Amendment for expanding the storage capacity of the spent fuel pool, approved by the NRC on 07/28/87
- MI0189-018A-TC07 3
. This Facility Change modified the HPSI Pump Mini flow Piping to allow enhanced pump surveillance. It involved installing throttling style valves to bypass flow around the restricting orifices to enable the HPSI Pump Flow to be varied.
SAFETY ANALYSIS
SUMMARY
Per this modification the newly installed valves are controlled (ie Locked Closed) during normal operation in accordance with Administrative Procedure 4.02.
The pump performance when operating at minimum recirculation flow is not degraded due to increased head loss as the increase in friction will be minimal in comparison to total system. If the new valve were to leak by during an emergency condition, control of the system can be maintained by closing the downstream valve.
The modification was seismically analyzed and installed.
The functional intent of the HPSI System remains unchanged as a result of this modification, and therefore the probability of occurrence or the consequences of an accident previously evaluated in the FSAR has not been increased.
The functional modification.
different type intent of the HPSI System remains unchanged as a result of this Therefore the possibility of an. accident or malfunction of a than any evaluated previously in the FSAR is not created.
The modification allows enhanced pump surveillance to ensure the pumps are capable of meeting operating requirements. Therefore the margin of safety as defined in the basis for any technical specification is not reduced.
FC-758 This Facility Change covers the replacement of four existing unqualified temperature elements (located in harsh environments) with qualified temperature elements, and the replacement of their respective cable with an environmentally qualified cable for those portions in harsh environment areas.
SAFETY ANALYSIS
SUMMARY
The new temperature elements and field cable are functionally equivalent to the existing components.
The new temperature elements are used to verify operation of the CCW and Shutdown Cooling Heat Exchangers in the event of a OBA.
The accidents which would *affect this component would be MSLB inside and outside of containment and a LOCA.
The new temperature elements and cable are environ-mentally qualified and will operate when challenged by the postulated harsh environment.
Therefore the probability of an accident has not been increased, the margin of safety would not be reduced below that represented by the design and operating basis of the Plant, and the consequences of an accident previ-ously evaluated in the FSAR is not ~ncreased. The new temperature elements and cable have a reduced probability of malfunction.
MI0189-018A-TC07 4
The equipment installed per this modification are functionally equivalent to the existing components, therefore the consequences of an accident as defined in the FSAR for malfunction of equipment important to safety would not be increased.
The failures modes and consequences of the new equipment would be the same.as the equipment to be replaced.
Therefore this replacement would not create an accident not previously evaluated in the FSAR *
. FC-760-04 This Facility Change relocates and replaces HPSI and LPSI valve control switch-es (8 HPSI Motor Operated Valve control switches and 2 LPSI Motor Operated valve control switches).
The replacement switches are interchangeable with the switches that are presently installed.
Safety Analysis Summary The probability of an accident previously evaluated in the FSAR is not in-creased because during accidents described in the FSAR in which these motor operated valves are required to function, the control switches provide no automatic function.
These switches can be used to operate the valves later in an accident should it be necessary.
Changing the location and type of the control switches does not increase the probability of an accident, especially considering that the replacement switches are interchangeable with the exist-ing switches, and improved reliability is the only aspect of the switch that is changing.
In fact, these changes could decrease the probability of an accident since the arrangement of the switches are improved.
The consequences of an accident previously evaluated in the FSAR is not in-creased because the improved switch locations will improve the operators assessment of the panels after an accident, thus making it easier to reduce the consequences of an accident.
The type of switch is being changed to improve its reliability.
The location of these switches on Panel C03 does not affect the reliability of the switch or its associated equipment/system.
The wiring used in this modification will be equivalent to or superior to the wire used now.
Therefore, the probability of malfunctions of equipment important to safety is not increased, and.due to overall improved switch reliability should be decreased.
The consequences of a malfunction of equipment important to safety will not be increased because the improved switch locations will improve the operators assessment of.the panels after a malfunction, thus making it easier to reduce the consequences of a malfunction.
Changing only the location of a switch on the control panel does not create the possibility of an accident or malfunction of a different type than any pre-viously evaluated in the FSAR, nor would changing the switch type to improve its reliability. This is assuming the fact that operators will look at the switch before they operate it, eliminating the possibility of an operator operating a*wrong switch because the location of it had been moved *.
MI0189-018A-TC07 5
The location or type of switches in the control panels is not used as the basis for any Technical Specification, the margin of safety as defined in the basis for any Technical Specification will not be reduced.
FC-789 This modification covered the Auxiliary Feedwater Flow Control.
The original Aux FW control valves were not capable.of controlling flow at a rate low enough to allow continuous Aux FW flow to the Steam Generators during Startup and Hot Shutdown conditions.
Intermittent filling which was used to meet operation requirements caused undesirable SG temperature swings and thermal cycling of the SG nozzle.
This modification installed safety grade bypass control valves around the Aux FW flow control valves CV-0736 and CV-0737 located in West Safeguards.
These valves are capable of controlling low flow rates to both SGs from electrical driven Aux FW Pump P-8C.
The valves are sized for flow rates of 20 to 120 gpm for Startup conditions and 20 to 100 gpm for hot shutdown conditions. They are designed to 1) fail closed; 2) close on a AFAS signal; 3) be closed when P-8C is not running, and 4) *have indication in the CR on AFW Status Panel when they are not fully closed.
This modification also replaced existing controllers. FIC-0736A and FIC-0737A with a model capable of controlling the Control Valves and able to be switched to manually control its respective bypass valve.
Safety Analysis Summary The modifications done under this Facility Change modified how the system controls flow, but does not change how the system is automatically started.
Therefore, this modification does not increase the probability of an accident previously evaluated in the FSAR.
The consequences of an accident previously evaluated in the FSAR are not increased by this modification.
Since the Controllers (FIC-0736A and FIC-0737) were replaced with equivalent controllers and have the same operability requirements as the previous con-trollers, the probability of malfunction of equipment important to safety has not been increased and the consequences of the new controller malfunctioning is not increased over that of the previous controller.
0This modification is consistent with the original design requirements and piping stresses were.within code allowables, and does not create the possibil-ity of or a malfunction of a: different type than any previously eyaluated in the FSAR.
The margin of safety as defined in the basis for any of the Technical Specifi-cations is not reduce~ by this modification.
MI0189-018A-TC07 6
FC-793 This modification was performed to facilitate maintenance and calibration of PCV-1008C which consisted of the following:
The installation of a manual valve downstream of PCV-1008C to allow isolation of the Waste Gas Surge Tank during maintenance and calibration of PCV-1008C.
The installation of a valve upstream of PCV-1008C.
In addition, a gauge has been installed between MV-CRW617 and LT-1008 to provide local indication of the equipment drain tank pressure.
Safety Analysis Summary The probability of an accident previously evaluated in the FSAR has not been increased due to this modification.
The design, material, and construction standards are equivalent to the original requirements, including st~esses in relation to code allowables.
FSAR Chapter 14 was reviewed with the conclusion that this modification will not affect any previously evaluated accident.
The consequences of an accident previously evaluated in the FSAR are not in-creased.
The addition is in an area that is not addressed by FSAR Chapter 14, and the modification will be performed consistent with the original construc-t ion code.
The probability of malfunctions important to safety is not increased.
The modification is a non-safety related portion of the system.
The addition of isolation valves around PCV-1008C does not increase the conse-quences of a malfunction of equipment important to safety. The modification is physically located in a non-safety related portion of the system.
The possibility of a malfunction of a different type is not created since the addition of isolation valves will be consistent with orig~nal design require-ments.
There are no Techni~al Specifications impacted by this modification, therefore there is no effect on any margin of safety.
FC-794 This Facility Change covered the modification to the Primary Coolant Pumps Controlled bleed-off vent to facilitate ILRT/LLRT, involving the addition of a normally closed vent valve downstream of containment isolation valves CV-2083 and 2099, reducing the required number of valves to be isolated and drastically reduce drain time when performing a Surveillance test.
MI0189-018A-TC07 7
Safety Analysis Summary The probability of an accident previously evaluated in the FSAR has not been increased because of this modification.
The design, material, and construction standards are equivalent to the original requirements, including stresses in relation to code allowables.
This modification does not affect any previously evaluate4 accident.
The consequences of an accident previously evaluated is not increased since the addition will be physically located downstream of containment isolation valves CV-2083 and CV-2099.
'!'.he probability of malfunction of equipment important to safety is not in-creased because the modification is physically located downstream of the containment isolation valves, first seismic restraint, and meets the original design specifications for materials and construction.
The addition of a tee and isolation valve does not increase the consequences of a malfunction of equipment important to safety.
The modification has no affect on the systems normal operation.
The possibility of a different type of accident is not created because the installation is consistent with original design requirements.
The possibility of a malfunction of a different type is not created.
The modification adds a vent and manual isolation valve downstream of the isolation valves.
If a leak were to occur it could be isolation by such valves.
There are no Technical Specifications impacted by this modification, thus there is no effect on any margin of safety.
FC-798 This modification covered the installation of two digital temperature indi-cators with alarming capabilities to be installed in Battery Rooms 01 and 02.
An alarm, common to both battery rooms, is activated when the temperature in either room drops to approximately 72°F.
Safety Analysis Summary This modification does not increase the probability or consequence of an accident previously evaluated in the FSAR, and does not introduce the possi-bility of a.n accident of a different type than any previously evaluated in the FSAR because the battery room temperature indicators are locally mounted and only used for shift surveillance readings rather than using temporary wall thermometers.
These devices or the common control room alarm from them are not required to function during or after an accident.
MI0189-018A-TC07 8
This modification does not increase the probability or consequence of a mal-function of equipment important to safety, and it does not introduce the*
possibility of a malfunction of a different type than any previously evaluated in the FSAR because the equipment does not perform any safety related function and a malfunction of the equipment would not have any effect on safety related equipment.
Failure of this equipment would be detected by the operator during shift surveillance and an alternate method of determining battery room temper-ature as indicated in procedures would be used.
The station batteries are designed to furnish their maximum load down to an operating temperature of 70°F as described in the FSAR.
There is no change to this value as a result of this modification, therefore, the margin of safety as defined in the basis for any Technical Specification is not reduced.
FC-799 This Facility Change consisted of two changes to the Palisades electrical system as follows:
- 1.
Wired the existing 25.2 MVA spare station power transfer 1-3 to allow operating the cooling tower buses "lF" and "lG" from station power *
- 2.
Provided a replacement 125 VDC battery system for the 345 kV switchyard.
Safety Analysis Summary A.
The addition of a second source of power to the "lF" and 111G11 buses does not increase the probability of an accident already analyzed in the FSAR; nor can it make possible the occurrence of an accident not reviewed in the FSAR, since the equipment being powered from these buses are not required during any accident discussed in the FSAR Section 14.
B.
The replacement of the 125 VDC battery system in the switchyard does not increase the probability of an accident already analyzed in the FSAR; nor can it make possible the occurrence of an accident not reviewed in the FSAR, since the function of the battery and chargers has not changed, only the size.
- c.
The probability of an equipment malfunction analyzed, or the possibility of a malfunction not analyzed by the FSAR is not increased by this modifica-tion; nor will the consequences of an equipment malfunction be increased since the equipment being powered from the "lF" and "lG" buses are not important to safety.
D.
The probability of an equipment malfunction analyzed, or the possibility of a malfunction not analyzed by the FSAR is not increased by this modifica-tion; nor will the consequences of an equipment malfunction be increased since the design of the battery system will allow the malfunction of any one part, namely the battery or one charger, and still maintain the 125 voe system.
MI0189-018A-TC07 9
---~----
E.
The c9nsequences of an accident already analyzed in the FSAR are not increased because: none of -the accidents assume the equipment powered from the "lF"' and* "19" buses needs to be operational.
F.
The consequences of an accident already analyzed in the FSAR does not increase because none of the accidents assume the switchyard battery or chargers needs to be operational.
G.
The 345 kV/4160-2400 V station power transformer 1-3 or the "lF" and "lG" buses are not discussed in the Technical Specification so the margin of safety is not reduced.
H.
The configuration of the switchyard battery system is not changed, so the reliability and availability of the 125 FDC system remains the same, thereby not reducing the margin of safety.
FC-801 The Facility Change covered the replacement of one of the Plant Air Compressors (C-2B) which supplies 200 SCFM with a larger one supplying a minimum of 320 SCF.
The original design intent was to be able to supply the entire plant supply required, 195 SCFM with one air compressor. It h8s been determined that one plant air compressor can no longer supply the entire plant since the plant
-air requirement's have reached 250 SCFM on the average.
However, with a 320 SCFM unit, all plant requirements including the FWP Building can be supplied.
This allows a larger margin of safety than the existing units.
Safety Analysis Summary The worst possible accident the failure of an air compressor could cause is the loss of Instrument Air.
The design of the system an~ redundancy of equipment and power supplies ensure that total loss of instrument air is highly improb-able.
This redundancy will be maintained since three air compressors will still be used.
The reliability of the system is increased since the new air compressor can handle the entire plant load, while the other two are available for standby or maintenance.
Therefore, the probability of an accident pre-viously evaluated in the FSAR is not increased.
Because of this modification the consequences of an accident previously evalu-ated in the FSAR is not increased.
The new unit is more reliable than the existing, thus reducing the possibility of malfunction of equipment.
Engineering Analysis evaluated the components in.
this system to ensure the new air compressor will not increase the probability or consequences of malfunction of any equipment.
Because the Compressed Air System is not addressed in the basis for any Tech-nical Specification the margin of safety is not reduced.
MI0189-018A-TC07 10
FC-803 This Facility Change covers the ISI Modifications to critical service pumps and piping to provide Inservice Inspection (SI) Pump Bypass Flow Instrumentation for HPSI Pumps P66A & B, LPSI pumps P67A & B, and Containment Spray pumps P54A, B & C.
The modifications are in response to the CPCo commitment correspondence to the NRC dated January 21, 1987, Attachment 1/2.1.2.
Safety Analysis Summary The probability of an accident previously e~aluated in the FSAR is decreased because the operational reliability of the ESS pumps will be increased.
The consequences of an accident previously evaluated in the FSAR are not increased.
New, accurate in-line or pipe and valve components will provide a basis to procedurally determine that safety-related ESS pumps are competent to perform within Technical Specification bypass flow requirements.
The IS! instrumentation components do not perform on a safety-related indica-tion or control function.
Therefore, the consequences of a malfunction of equipment important to safety is not increased, and the possibility of an accident or malfunction of a different type than any previously evaluated in the FSAR is not created.
The margin of safety as defined in the basis for any Technical Specification is not reduced because they are not altered by the addition or replacement of any ISI Instrumentation.
FC-806 This Facility Change modified the Spent Fuel Pool Cooling line as follows:
Three radiological clean-outs were installed on the Spent Fuel Pool cooling line.
The North Tilt Pit Drain Line was. deleted and capped.
This modifica-tion included the installation of a flanged spool piece with a drain valve in the South Tilt Pit Drain Line.
The spool piece was replaced with a micron filter to drain the South Tilt Pit.
Safety Analysis Summary The probability of an accident as previously evaluated in the FSAR is not increased.
Previously the North Tilt Pit Drain was capped.
The modification removed the abandoned piping.
The remaining piping and valves have the same operational configuration but redundant piping and a valve have been removed.
The South Tilt Pit Drain Line configuration for draining the South Tilt Pit with the micron filter installed is Non-Q.
The modification does not increase the consequences of an accident previously evaluated in the FSAR.
MI0189-018A-TC07 11
The probability of malfunction or consequences of a malfunction of equipment important to safety is not increased.
The possibility of an accident or malfunction of equipment of a different type than any previously evaluated in the FSAR is not created, and the margin of safety as defined in the basis for any technical specification is not reduced.
FC-807 This Facility Change covered the installation of the LPSI Pump Low Discharge Pressure Alarm circuitry.
This circuit aids the operator in the early detec-tion of a loss of shutdown cooling system flow due to vortexing or a loss of NPSH to the LPSI pumps during PCS partially drained operations.
Safety Analysis Summary The modified circuit does not perform any control functions and utilizes existing spare contacts and conductors to alert the operator that a loss of shutdown cooling may have. occurred.
This modification does not change the probability of occurrence of an accident or the consequences of an accident which was previously analyzed in the FSAR, nor does it create the possibility of an accident not analyzed in the FSAR.
The modification was made using standard electrical practices for w1r1ng.
The actual circuit is a non-channelized alarm circuit and provides alarm indication and no control or safety actuation signals.
The new indicator which provides the alarm signal meets th.e requirements for Class IE service and has been seismically tested by CPCo.
Based on this, the probability of a malfunction of equipment important to safety is not increased, nor is the possibility of a malfunction of a different type than any already analyzed in the FSAR.
This instrument is not covered in the basis for any Technical Specification, thus the margin of safety is not affected.
FC-811 This Facility Change covers the procurement and installation of the Service Water System bypass flow piping header.
This header was added to facilitate ISI Surveillance testing.
Safety Analysis Summary This Facility adds a 6 11 flowmetering flow test header in the vicinity of SWS pumps, a t:.P direct-reading flow gauge, direct reading pressure gauges; neces-sary manual isolation valves and piping supports.
ISI Surveillance testing with the added instruments now provides a direct gauge readout basis to determine SWS pump flow{s) and discharge pressure conditions MI0189-018A-TC07 12
for each of the pumps.
Accident probability is decreased since surveillance testing determinations assure that equipment remains competent to perform its Technical Specification tasks within allowable limits.
This modification does not alter current operating practices.
Therefore the
- consequences of an Accident previously evaluated in the FSAR is not increased.
The Q0-14 Technical Specification Surveillance test procedure is utilized during and before the activity and is used to restore equipment lineup and return the SWS to operating mode.
ISI Technical Specification Surveillance testing capabilities are added so that direct instrument measurement techniques may be applied.
These !SI techniques decrease,the probability of malfunction of equipment important to safety.
The consequences of a malfunction of equipment important to safety is not increased.
The possibility of an accident of a different type than any pre-viously evaluated in the FS~.R is not created because of this modification.
Any !SI testing which requires SWS valve lineup is procedurally controlled for the three pumps by Technical Specification Test Q0-14.
This modification does not create a different type of malfunction than any previously evaluated in the FSAR based on the non-safety related displays, !SI surveillance test administrative controls and ASHE XI controlled piping modifi-cation techniques used.
The plant configuration, after !SI test procedure completions is functionally the same, and performs the same as it did before the modification.
Technical Specification margins of safety remain unaltered by this modifica-tion.
FC-812 This Facility Change modified the Safety Injection System Test Circuitry and the control -circuitry for non-critical service water isolation valve CV~l359 to allow the SIS contacts that close the valve to be tested without having the valve itself close.
Safety Analysis Summary Because of this modification the probability of an accident previously evalu-ated in the FSAR is not increased.
One initiating event that has a remote possibility of leading to an accident described in the FSAR is an unanticipated loss. of non-critical service water.
This modification does not effect the.
probability of this event.
Presently a transient of this kind could be caused by an operator failing to open.the manual bypass valve around CV-1359 during Tech Spec Test Q0-1.
Because of this modification, this failure is eliminated and is replaced by a failure of the SIS test blocking relays. It is felt that a relay failure has a lower probability of occurrence and therefore the proba-bility of an accident previously evaluated in the FSAR is marginally decreased.
MI0189-018A-TC07
- 13.
The consequences of an accident previously evaluated in the FSAR has not been increased.
The modification decreases the probability of a malfunction of CV-1359 because it isolates on demand.
However, instead of cycling CV-1359 every quarter, this modification makes it such that it will need to be cycled only every refueling outage. This could cause an increase in the probability of a malfunction of CV-1359 to isolate.
The overall effect of this modifica-tion is felt to be a decrease in the probability of a malfunction of CV-1359 to isolate, or an improvement in overall safety.
The consequences of a malfunction of equipment important to safety as previous-ly described in the FSAR is not increased.
The modification does not create the possibility of an accident of a different type than any previously evalu-ated in the FSAR.
One failure mode added by this modification is a failure of the blocking relay contacts to reopen after their function is accomplished.
This prevents the SIS contact from performing its function.
This is an extremely small risk ans is consistent with the other SIS blocking relays that are used to block actuation of other equipment.
Therefore this design is not entirely new.
This modifi-cation does not create the possibility of a malfunction of a different type than any previously evaluated in the FSAR.
The margin of safety in the basis of the Technical Specifications is not affected by this modification, therefore, the margin of safety as defined in the basis for the Technical Specification is not reduced.
FC-814 This Facility Change covered the Core 8 Reload in the 1988 Refueling Outage.
Safety Analysis Summary The Core 8 Reload does not involve any changes in-operating procedures, only the replacement of discharged fuel assemblies with fresh fuel assemblies, and 16 previously discharged assemblies modified to provide shielding to critical pressure vessel welds.
These hardware changes are not of the type which would be expected to initiate a new type of accident, and the probability of an accident previously evaluated in the FSAR was not increased.
The basic mech-anical and thermal-hydraulic design of the core and fuel assemblies remains unchanged.
The Core reload change did not increase the consequences of an accident pre-viously evaluated in the FSAR.
Core 8 has a modified reactor protection system and increased peaking factors which could have an impact on accident conse-quences, but these impacts have been evaluated in two separate safety evalua-tions previously performed and submitted to the UNSRC for approval of appro-priate Technical Specification changes.
Five additional changes in Core 8 are:
MI0189-018A-TC07 14
- 1.
Core 8 wi 11 include 16 more Gd203 containing fuel assemblies than Core 7 and 16 assemblies will contain 6 w/o Gd203 as compared to all other Gd203 which have 4 w/o.
The increased number of Gd203 rods and the higher loadings of Gdz03 will have no impact on the consequences of any accid~nt previously analyzed in the FSAR.
- 2.
Sixteen Batch*H assemblies have been reconstituted to replace four rows of fuel rods with four rows of stainless steel rods, which were analyzed for their thermal hydraulic behavior.
- 3.
Four new fuel assemblies in the "L" batch* are test assemblies which contain a new grid design which provide increased lateral crush strength and improved thermal performance.
- 4.
Five fuel assemblies, one from J batch and four from K batch, were modified to replace failed fuel rods with zircalloy inert rods.
- 5.
Fuel Assembly K-028 which lodged in the UGS when the UGS was lifted has had its upper tie plate exchanged with the upper tie plate from another assem-bly, which is essentially the same.
The Core 8 fuel loading does not affect reactor system hardware or procedures and thus does not affect equipment important to safety.
probability of malfunction or the consequences of a malfunction of important to safety is not increased.
operating Thus the equipment The possibility of an accident or the malfunction of a different type than any previously evaluated in the FSAR is not cr.eated by Core 8 loading.
The margin of safety as defined in the basis for any Technical Specification is not reduced by Core 8 loading.
FC-820 This Facility Change covered the Support Building Emergency Siren Addition.
These two emergency sirens are electrically powered by the Service Building batteries. Also, the three existing Service Building emergency sirens which were fed from the Station Batteries were modified to be fed from the Service Building batteries.
Safety Analysis Summary Removing the Service Building emergency sirens from the Station Batteries will reduce the load from the Station Batteries, thus the Station Batteries will operate longer without shedding nonessential loads, reducing the probability of an accident or malfunction of equipment important to safety during a complete loss of AC power.
The modification reduces the probability of an accident or malfunction of equipment important to safety.
The margin of safety as defined in the basis for any Technical Specification is not reduced.
MIO 18 9-01BA-TCO7 15
FC-830 This Facility Change covered the modification of the Condenser Off Gas Sampling System, including the installation of two vacuum gauges, replacement of the moisture separator with a drain trap, and installation of bypass valves around desiccant dryer and drain trap.
Safety Analysis Summary This modification was done to provide more reliability to the Condenser Off Gas Sampling System.
The equipment does not provide any safety function and does not increase the probability or consequences of an accident evaluated in the FSAR and does not increase the possibility of an accident or malfunction of a different type than previously evaluated in the FSAR.
The equipment modified is not associated with safety related equipment and will not increase the probability or consequences of a malfunction of equipment important to safety.
This equipment is not described in the Technical Specifications, therefore the margin of safety as defined in the basis for any Technical Specification is not reduced
- sc-86-162 This Specification Change covers the addition of Seismic Restraint Brackets to Power Supply's PS-2021 and 2022, and the performance of a SQUG Seismic Analysis for operability during a seismic event.
These power supplies are required to be a Category 1 per Reg Guide 1.97, and need to be able to perform in the event of an earthquake/seismic event *. The addition of the brackets prevents the power supplies from coming out of their octal sockets.
Safety Analysis Summary The addition of seismic restraints to the existing CST Level Instrument Loop power supplies does not affect the operation in any manner other than insuring that the power supply remains in place during postulated seismic events.
The SQOG methodology for determining seismic ruggedness is based on evaluation of the effects of actual seismic events on installed equipment and is an accepted methodology.
For these reasons, the probability and the consequences of accidents previously evaluated in the FSAR are not increased; the probability 0of a malfunction of these power supplies is decreased by these restraints; the consequences of a malfunction of the power supplies is not changed.
The addition of these restraints does not create the possibility of an accident or a malfunction of a different type than previously evaluated in the FSAR.
The power supplies are not specifically in the basis for any Technical Specifi-cation.
MI0189-018A-TC07
. 16
SC-87-148 This Specification Change covered the replacement of existing Radiation Monitor equipment for the Evaporator Control Panel Area.
The new replacement requires only a simple yearly calibration.
The old system has been replaced because the equipment is outdated.and prone to failure.
The old system functioned in an analog manner while the replacement functions digitally.
Safety Analysis Summary The old monitoring system had a remotely operated integral radiation check source while the new system uses an electronic check source via a change in the detector high voltage. This replacement improves the reliability of the evaporator control panel area monitor and still allows its correct operation to be tested.
The replacement does not affect the description nor the range and sensitivity of the system as described in the FSAR.
The monitors will continue to be tested in a manner similar to that in the past.
No previously evaluated accident can be caused or affected by this replacement.
Because of this replacement the area monitor will operate more reliably, there-fore its ability to detect radiation increases is improved and the consequences of an accident are not be increased.
Since the new equipment operates more reliably than the old, the probabiliity of a malfunction is reduced.
The new monitor functions digitally, reducing the possibility of drift from calibrated values.
Malfunction of the new monitor is displayed on the readout because the system performs self diagnostics and displays error codes* if a problem exists.
No other equipment important to safety is actuated or affected by the a.rea monitor.
No accident of a different type than any previously evaluated in the FSAR can be caused by this replacement.
There is no possibility of a malfunc-tion of a different type than any previously evaluated in the FSAR.
There are no margins of safety based on area monitor operation.
The change to the Technical Specifications will not cause an unreviewed safety question since only the method of monthly verifying of operability is being changed.
SC-87-156 This Specification Change was to cover the change of Aux FW pump start delay times and increase the air pressure on flow control valve operators.
MI0189-018A-TC07 17
Safety Analysis Summary The current design basis for the delay time for automatic initiation of AFW delivery post AFAS is listed in the FSAR as 120 seconds.
This basis was determined to be a design criterion and not a regulatory requirement.
Delay of AFW delivery by an additional 57 seconds was evaluated using the method devel-*
oped in Engineering Analysis EA-PAL-AFW-870831 and was found to be acceptable providing the AFW flow control valve setpoints were increased from 150 gpm to 155 gpm.
For the 177 sec delay and with 155 gpm to each SG, the steam genera-tors will remain as an acceptabl* heat sink for the limiting transient, Loss of Feedwater Flow Incident. Therefore the probability or consequences of an accident is not increased.
The proposed AFW pump start sequence timing reduces the probability of over-feeding the intact steam generator during a Steam Line Rupture Incident by incorporating more margin for control valve and pump operation, and thereby reduce the likelihood of an undesirable automatic start of more than one AFW pump.
SC-87-344 This Specification Change covers the change to setpoints to allow for the arming of LTOP at higher temperatures.
Safety Analysis Summary This setpoint change is a change to the temperature switch which allows the
~
arming of LTOP.
The value for arming is being increased from 300°F to 430°F.
This allows LTOP to be armed sooner than previously and is therefore more conservative.
Therefore, the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evalu-ated in the FSAR is not increased.
The new setpoint allows the LTOP system to be armed sooner than before, there-fore it is capable of providing protection sooner, and the possibility of an accident or malfuncti9n of a different type than any evaluated previously in the FSAR is decreased.
Technical Specifications require that the system be operable whenever the PCS temperature falls below 250°F.
A setpoint of 430°F is more conservative and therefore does not affect the margin of safety.
SC-87-375 This Specification Change covers the replacement of relays SSX-3 and SSX-4 which affect CV-0727 and CV-0749, and CV-0736A and CV-0737A.
MI0189-018A-TC07 18
Safety Analysis Summary The probability and consequences of an accident not previously evaluated in the FSAR is not affected by this change.
The replacement of these relays decreases the probability/consequences of malfunction of equipment important to safety because the relays are designed to operate in instrument circuit. The relays are of equal weight {or less) due to seismic requirements and have contacts which do not tarnish because of low operating voltage/current.
The relays are seismically qualified per IEEE 344.1975.
The possibility of an accident or malfunction of a different type than any previously evaluated in the FSAR is not created because each relay will be replaced separately using a lift/land synopsis as part of the work order, and testing by Operations after the work is completed during a plant shutdown.
The margin of safety as defined in the basis for any Technical Specifications is maintained because these replacement relays increase the reliability of equipment that is specifically covered under the Technical Specifications.
SC-88-010 Specification Change SC-88-010 involves the removal of hydraulic snubbers SNB-74 {HG/GC11-S850.2), SNB-75 {HGR/GC11-S858.l) and SNB-76 {HGR/GC11-S858.2) and replacement with equivalent capacity struts. *These snubbers are all located on the Primary Coolant System on the Pressurizer Relief Valve Discharge Piping.
PE&C Calculation PSR 75, which uses design and analysis crit.eria contained in Sections 5.7 and 5.10 of the FSAR, documents the acceptability of this change.
This modification eliminates the cost and radiation exposure
'associated with inspection maintenance and testing of these snubbers.
Safety Analysis Summary
- 1.
The accidents described in Section 14 of the FSAR have been reviewed.
The modification has been shown to be acceptable using design and analysis criteria contained in the FSAR.
Therefore, the probability of previously evaluated accidents are not increased.
- 2.
The consequences of an accident previously evaluated in the FSAR have not been increased because the modification meets the design and analysis criteria contained in the FSAR.
- 3.
The probability of malfunction of equipment important to safety is not increased by this modification.
The referenced piping supports and piping system still meet the design and analysis criteria contained in the FSAR.
- 4.
The consequences of a malfunction of equipment important to safety have not been increased by this modification.
The Pressurizer Relief Valve piping system and supports still meet the design and analysis criteria contained in the F~AR.
MI0189-018A-TC07 19
I
- 5.
The possibility of an accident of a different type than any previously evaluated in the FSAR has not been created by this modification because the design and analysis criteria contained in the FSAR have been met.
- 6.
The possibility of a malfunction of a different type than any previously evaluated in the FSAR has not been created by this modification because the design and analysis criteria contained in the FSAR have been met.
- 7.
The Technical Specification inspection and testing requirements are based on a percentage of the number of safety related snubbers installed in the plant.
Removal of snubbers using FSAR design and analysis criteria does not reduce the margin of safety as defined in the Technical Specification because the same percentage of safety related snubbers will be inspected and tested.
SC-88-048 This Specification Change involved the replacement of three recorders with a more reliable model and to standardize plant equipment.
Safety Analysis Summary This SC replaces Primary Makeup Water Flow Recorder FRC-0210A, Concentrated Boric Acid Makeup Flow Recorder FRC 02108, and Primary Loop Differential Temperature Recorder DTR-0111/0121.
The recorders are located in the main Control Room.
The existing recorders are being replaced to reduce maintenance requirements and to standardize plant equipment.
The new recorders are func-tionally identical to the previously existing recorders.
The changes made to the FSAR by this SC are editorial in nature.
The P&IDs were revised to more accurately depict the hardware configuration that present-ly exists in the Plant.
The probability of an accident previously evaluated in the FSAR is not in-creased by this modification.
The consequences of an accident previously evaluated in the FSAR are not increased because there were no previously evaluated accidents which are affected by this modification.
The recorders being replaced are not safety related. The existing isolation devices for. these recorders are not being changed.
Therefore, the probability of a malfunction in the recorders affecting equipment important to safety is unchanged.
Because the new recorders interface with other plant equipment in exactly the same manner as the recorders they replaced, the consequences of a malfunction MI0189-018A-TC07 20
The new recorders are functionally identical to the preexisting recorders. They receive the same input signals through existing wiring.
They are powered from_
the same source as the existing recorders.
The output of the recorders is the same, so that the Operators receive the same visual information. Therefore, the possibility of an accident of a different type than previously evaluated being created does not exist, and the possibility of a malfunction of a dif-ferent type than any previously evaluated being created does not exist.
The Technical Specifications do not define any margin of safety that is asso-ciated with the function of these recorders.
SC-88-145 This Specification Change replaced the Component Cooling Water Packing Glands with Mechanical Seals to eliminate pump leakage.
Safety Analysis Summary Because of this modification the probability of an accident has not been increased.
The overall system performance of the CCW system is not affected in a manner which could lead to an accident.
The modification does not have any affect on the consequences of any accident previously evaluated in the FSAR.
The modification increases pump reliability by providing *an improved sealing surface between casing bore and seal 0-Rings while meeting original design specification. Therefore the probability of malf~ction of equipment important to safety is not increased.
The consequences of a malfunction of equipment important to safety -is not iJ;.lcreased.
Consideration of realistic failure modes associated with this modification revealed no impact on the FSAR accident analysis, no new accidents, no analyzed malfunctions, and new new malfunction will result.
This modification does not reduce the margin of safety as defined in the basis for the applicable Technical Specifications.
SC-88-185 This modification was made to revise the stroke time requirements for SIRW Tank and Containment Sump Discharge Valves.
MI0189-018A-TC07 21
Safety Analysis Summary The evaluation of stroke times for the SIRW Tank and Containment Sump Discharge Valves considers the following items:
- 1.
Mixing of hot and cold pump suction water subsequent to an RAS.
- 2.
Ensuring containment flooding level is not increased beyond level for which equipment is EEQ qualified in regards to flooding.
- 3. Maintaining SIRW Tank reserve of approximately 20,000 gallons as required by the Tech Specs.
- 4.
Ensuring containment sump water is not recirculated back to the SIRW Tank *.
5 *. Maintaining an adequate overlapping stroke time between SIRW Tank and Containment Sump Discharge valves to ensure an uninterrupted supply of pump suction to the Engineering Safeguards pumps.
- 6.
Insuring proper valve and system operation in regards to potential compon-ent malfunction.
The probability or consequences of an accident previously evaluated in the FSAR is not increased by this modification.
The probability or consequences of malfunction of equipment important to safety is not increased, and the possi-bility of an accident of a different type than any previously evaluated in the.
FSAR is not created.
The possibility of a malfunction of a different type than any previously evaluated in the FSAR is not created, and the margin of safety as defined in the basis for any Technical Specification is not reduced.
sc-aa~196 This Specification Change upgrades the Critical Function Monitoring System (CFMS) disk drive with a faster, more reliable one with a high capacity. This CFMS is a computer based data acquisition system.
Safety Analysis Summary Other than size, the two disks are functionally equivalent.
The CFMS is an operator aid, does not perform any control function, and is not a nuclear boundary.
It is not required to survive a DBA.
The probability of or the consequences of an accident previously evaluated in the FSAR is not increased by this modification.
Because isolation between the CFMS and safety components is not changed from its description in the FSAR, the probability or consequences of malfunction of equipment important to safety is not increased.
MI0189-018A-TC07 22
The CFMS is not required to perform any safety function.
Therefore the pas-*
sibility of a malfunction of a different type, or an accident of a different type than any previously evaluated in the FSAR is not created.
Because the CFMS is not covered in the Technical Specifications, the margin of safety as defined in the basis of any Technical Specification is not reduced.
SC-88-197 This Specification Change modified the new fuel elevator to improve the design capacity and safety.
The new design is able to support, raise and lower two fuel assemblies and will have a mechanical brake to back up the two existing electrical brakes.
Safety Analysis Summary The fuel handling incident (FSAR 14.19) is the applicable evaluation concerning this modification.
The probability of this accident has not been increased because the modification provides safety features sufficient to support the increased loading.
In addition, strength limits of the elevator structure are not violated; the elevator frame has been shown to be capable of supporting
~3010 lbs compared to the maximum weight of two fuel bundles of 2600 lbs in water, and the elevator cable size change from 3/8" to 1/2" maintains a desir-able safety factor of five on the cable. The probability of an inadvertent criticality incident with two fuel assemblies in the elevator is not increased due to the fact that the elevator cells are far enough apart such that the resident fuel assemblies do not interact sufficiently to increase the reactiv-ity of either assembly.
Additionally, the presence of ~1720 ppm boron will further affect no criticality concern regarding the elevator geometry.
The fuel handling incident assumes a drop followed by a tilt to cause the radiological release.
The probable drop associated with the fuel elevator would be confined within the elevator itself with no tilt involved.
- Further, one of the cells in the fuel elevator is enclosed which would provide some protection to the enclosed fuel assembly from protrusion.
Because of these limiting factors, it is reasonable to assume that the number of fuel rods failed during the accident would be no greater than the one outer row (13 rods) determined in. the fuel handling inc;ident analysis.
The consequences of an accident is not increased.
The fuel elevator modification improves the ability of the elevator to prevent an assembly drop by the addition of a mechanical brake.
The increased load of two fuel assemblies remains within the design limits of the elevator structure with the increased cable size. Therefore, the probability of malfunction of equipment important to safety is not increased.
If the elevator should fail and fall with two assemblies, the consequences of the malfunction would not increase because there is no interaction between the two assemblies, nor with any other assembly in the fuel pool. If something HI0189-018A-TC07 23
could happen to cause this interaction, the cask drop analysis shows that up to 22 assemblies could be damaged without exceeding 10CFRlOO limits, bounding any possibility.
The possibility of an accident of a different type than previously evaluated in the FSAR is not created.
Since no change in the overall operation of the elevator will occur, the possibility of a malfunction of a different type than previously evaluated in the FSAR is not created.
The margin of safety as defined in the basis for any Tech Specs is not reduced because based on the definition of heavy loads described in Tech Spec 3.21, the two fuel assemblies together in the elevator can be considered a heavy load.
For a given drop of the assemblies in the elevator, the four evaluation criter-ia of NUREG-0612 are satisfied as follows:
A.
Radiological releases from the drop would fall well within the limits of 10CFRlOO.
B.
For the elevator geometry and the confined area of the elevator within the fuel racks, criticality would not be possible with normal dissolved boron levels in the pool.
C.
The drop of two assemblies on the spent fuel pool floor would be insuf-ficient to puncture the floor liner beyond the makeup capabilities of the fuel pool makeup system.
D.
Dropping of the two fuel assemblies would not result in damaging of any equipment requi~ed for safe shutdown.
SC-88-223 (Steam Generator E-50A)
& SC-88-224 (Steam Generator E-SOB)
This Specification Change covers the removal of a number of tubes from service on Steam Generator using a welded tube plug.
The tubes plugged are listed on the "Palisades 1988 Plugged Tube List" supplied by ISI.
The Change also covers the return of the Steam Generator to an operable condition.
Safety Analysis Summary This modification covers the tube plugging of tubes in the Steam Generator is specified in the 1988 Steam Generator Eddy Current Test Outage Plan.
Removing defective or degraded tubes from service greatly decreases the possi-bility of a primary to secondary leak.* The number of tubes removed from service does not exceed the available plugging margin per Engineering Analysis EA-SC-88-223-01 and Advanced Nuclear Fuels Analysis ANF-87-150 NP.
-HI0189-018A-TC07 24
The plugging was done using qualified plugs and procedures.
The modification removes from service the tubes which exceed Palisades Plugging Criteria, and *is a routine ac.tivity.
The removal of Steam Generator Tubes (passive elements in the system) does not affect the probability or consequences of an accident previously evaluated in the FSAR nor create an accident or malfunction of a different type than any previously evaluated in the FSAR.
The probability of malfunction or consequences of a malfunction of equipment important to safety is not increased by the plugging.
The margin of safety as defined in the basis for any Technical Specification is not reduced.
SC-88-311 The original specifications for Motor Control Centers EB-1 and EB-2 call for install.ation of drip hoods on the top of these centers.
Actual field condi-tions reflect that drip hoods were never installed.
This Specification Change covers the sealing of.the tops of the Motor Control Centers as an alternative to driphoods.
Safety Analysis Summary Waterproofing, using RTV sealant, on the top seams of EB-1 and EB-2 Motor Control Centers is used as an alternative method for driphoods due to space limitation.
Use of this approved RTV Sealant provides for water protection superior to that provided by the driphoods because water spray could get underneath due to the design of mounting a shield 311 above the top of the Motor Control Centers.
Per discussion with Company Fire Protection Engineering this alternative method is equivalent to installed driphoods.
This modification does not increase the probability or consequences of an accident of a different type than any previously evaluated in the FSAR.
It does not increase the probability or consequences of malfunction to equipment important to safety, nor does it reduce the margin of safety as defined in the basi.s for any Technical Specification.
An FSAR change request will be submitted for the above.
SC-88-328 This Specification Change replaced the air trip valve on the control air line for the Primary Coolant Pump controlled bleed off line (CV-2191) and replaced it with an In-Line check valve and added test taps.
MI0189-018A-TC07 25
Safety Analysis Summary The FSAR does not accurately reflect the components installed in the controlled air line to CV-2191.
An FSAR change is necessary but it is editorial in nature only.
This Specification Change does not affect the probability or consequences qf an accident previously evaluated in the FSAR, nor does it affect the probability or consequences of a malfunction of equipment important to safety. The possi-bility of an accident or a malfunction of a different type than any previously evaluated in the FSAR is not created.
The margin of safety as defined in the basis for any Technical Specification is not reduced.
- This Specification Change increased the set pressure of PCV-0520, Auxiliary Feedwater Pump Air Pressure Regulator from 100 psig to 112 +/- 10 psig, which results in a larger closing force.
Safety Analysis Summary The FSAR contains a drawing which lists the air pressure for this valve.
Increasing the air pressure should help assure valve closure.
The increase in air pressure increases the force used to drive the wedge into the seat.
The increased psig is below the reconmended maximum.
Friction test data indicates that the change in air pres.sure has little effect on the break away force.
Therefore, the probability of a malfunction of equipment important to safety is not increased.
The probability of an accident or the consequences of an accident previously evaluated in the FSAR is not increased.
The consequences of a malfunction of equipment important to safety is not increased.
The possibility of an accident or malfunction of a different type than any previously evaluated in the FSAR is not created.
The margin of safety as defined in the basis for any Technical Specification.is not reduced.
SC-88-358 This Specification Change removed nine tubes from service using a welded tube plug, and five plugs were replaced in Steam Generator E-508.
Tubes plugged were selected based on Inservice Inspection results. Tubes plugged are listed on the "Palisades December 1988 Plugged Tube List".
HI0189-018A-TC07 26 /
Safety Analysis Summary Removing defective or degraded tubes from service greatly decreases the possi-bility of a primary to secondary leak.
Removing these plugs does not exceed the available plugging margin.
The plugging was done using qualified plugs and procedures.
The change removed suspect tubes from service. This is a routine activity.
The removal of tubes from service (passive elements in system) does not affect the probability or the consequences of an accident or malfunction of equipment important to safety, nor create a new accident or malfunction of equipment as previously evaluated in the FSAR.
Up to 847 additional tubes can be plugged between the two Steam Generators.
Since plugging the tubes specified above does not exceed the available plugging margin, the margin of safety as defined in the basis for any Technical Specif i-cat ion is not reduced.
Special Test T-95 The purpose of this Special Test is to provide surveillance for the initial approach to critical for a new Palisades core.
Safety Analysis Summary The operational steps performed within this test are bounded by present Safety Analysis for the original and subsequent new cores.
The probability of occur-rence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the FSAR is not increased due to the perform-ance of this test. The procedure provides a conservative means to achieve criticality. Thus, the possibility for an accident or malfunction of a dif-ferent type than any evaluated previously i~ the FSAR is not created.
Themargin of safety as defined in the basis for any Technical Specification is not reduc*ed; Criticality is approached from the All Rods Out configuration which allows for maximum Available Shutdown margins.
Tavg is maintained above 525°F which is equivalent to the Technical Specification margin allotted for minimizing the positive value of moderator temperature coefficient when approaching criticality with a new core.
Special Test Procedure T-163 The purpose of this Special Test is to identify which fuel assemblies have cladding perforations.
(Fuel sipping in Spent Fuel Pool)
MI0189-018A-TC07 27
Safety Analysis Summary The probability or the consequences of an accident or malfunction of equipment important to safety previously evaluated in. the FSAR is not increased because the fuel sipping equipment provides an accurate technique for identifying fuel suspected of cladding perforations by monitoring any fission bases released from an irradiated fuel assembly which has been isolated in a vacuum-tight container.
Equipment malfunction could cause a loss of air and/or water to the container and an inability to open the container lid automatically forcing the temperature inside the container to rise. The probability of this occurring is low based on previous operation of our system and similar General Electric Sip Systems at other utilities. The temperature rise based on an analysis perform-ed by General Electric would not be enough to damage the assembly and would be adequately cooled.
This procedure does not constitute an unreviewed safety question.
The probability of an accident of a different type than previously evaluated in the FSAR will not be created because the vacuum sip system will handle only one assembly at a time and failure of the system would be considered a fuel hand-ling accident which is covered by the FSAR.
- The margin of safety as defined in the basis for any Technical Specification is not reduced.
Special Test T~l95 The purpose of this Special Test is.to determine a PCS hot full power mass flow rate using the secondary calorimetric method.
Safety Analysis Summary The calorimetric method for calculating PCS flow requires the determination of bulk average temperatures in the cold and hot legs of the reactor.
Because of incomplete mixing in the reactor upper plenum and hot legs, temperature strati-fication may occur in the hot legs. Therefore, a correction factor is required to adjust the indicated hot leg temperatures to a bulk average temperature.
The probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the FSAR is not increased and the possibility of an accident or malfunction of a different type
. than any evaluated previously in the FSAR is not created.
The margin of safety as defined in the basis for any Technical Specification is not reduced by the performance of this test.
Special Test T-203 This test demonstrates the performance of the steam pressure controller (PCV-052la) for the turbine driven auxiliary feed pump (P-88) by measuring the steam pressure control stability.
MI0189-018A-TC07 28
Safety Analysis Summary The test was conducted within equipment design and does not affect the prob-ability or consequences of an accident previously evaluated in the FSAR.
Testing reduces the probability of a malfunction of equipment by demonstrating the equipment's performance, which includes measuring steam turbine inlet pressure during turbine start as a function of controller settings; measuring steam pressure as a function of CV-0522B valve position at minimum flow load; taking high accuracy pump discharge pressure data at two different flows; and measuring the stability of the st~am pressure control systems (PCV-0521 and turbine governor).
The possibility of an accident or malfunction of a different type than pre-viously evaluated in the FSAR is not created.
The margin of safety as defined in the basis for any Technical Specification is not reduced durin~ this test.
Special Test T-223 This Special Test Procedure was used in part, to set the CCW flow to the spent fuel heat exchangers.
Safety Analysis Summary The probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the FSAR was not increased by this procedure.
The possibility of an accident or malfunction of a different type than any evaluated in the FSAR was not increased by this procedure.
The possibility of an accident or malfunction of a different type than any evaluated in the FSAR is not created.
Because the CCW system is not required during cold shutdown, the margin of safety as defined in the basis for any Technical Specification is not reduced.
Special Test T~229 The purpose of this test is to measure moisture carryover of the steam gen-erators. This value will be used in two ways:
- 1) to determine the effective-ness of the moisture removal equipment in the steam generators, and 2) to provide for a more accurate plant heat balance.
Safety Analysis Summary This test measures the amount of moisture carryover in the steam leaving the steam generator. It does this by measuring concentrations of an injected tracer chemical at various points of the turbine cycle.
The test results will increase the plant's safety by allowing for a more accurate heat balance calculation.
The probability of occurrence or the consequences of an accident MI0189-018A-TC07 29
or malfunction of equipment important to*safety previously evaluated in the FSAR is not increased, and the possibility of an accident or malfunction of a different type than any evaluated in the FSAR is not created because of this test, and the margin of safety as defined in the basis for any Technical Specification is not reduced.
Special Test T-249 The purpose of this test is to demonstrate valve operability against differen~
tial pressure for the High Pressure Safety Injection, Redundant High Pressure Safety Injection, and Hot Leg Injection motor operated valves.
Safety Analysis Summary This test was performed as part of the Palisades response to IE Bulletin 85-03 "motor operated valve common mode failure during plant transients due to improper switch settings." This test verifies the stroke operability of the High Pressure Safety Injection, Redundant High Pressure Safety Injection, and Hot Leg Injection motor operated valves, and was done under the maximum expect-ed differential pressure that the valves would see during the design accident conditions covered in FSAR 6.1.
This test was performed during cold shutdown.
The possibility of exceeding reactor vessel pressure vs temperature limits is addressed by ensuring the reactor vessel load is removed.
The probability of occurrence of an accident or malfunction of equipment important to safety previously evaluated in the FSAR is not increased.
The valves and system were tested within permanent plant system parameters and within the operating boundary specified in the FSAR.
Therefore, the possi-bility of an accident or malfunction of a different type not previously evalu-ated in the FSAR is not increased.
The margin of safety as defined in the basis for any Technical Specification is not reduced.
Special Test T-250 This test was performed to test the operability of one Auxiliary Feedwater Motor Operated valve in the post-accident situation, and was performed in response to IE Bulletin Number 85-03.
This procedure was performed as part of Palisades response to IE Bulletin 85-03, "Motor operated valve conman mode failure during plant transients due to improper switch settings." During this test the stroke time operability of M0-0753.was verified during the maximum expected differential pressure that the valve would be susceptible to during the designed accident conditions listed in MI0189-018A-TC07 30
the FSAR.
During the performance of this test the operating limits of the system were within the bounds of the accident analysis listed in the FSAR.
Therefore, the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the FSAR is not increased.
The possibility of an accident or malfunction of a different type than any evaluated previously in the FSAR is not created because the maximum differen-tial pressure is within the operating boundary specified in the FSAR.
Because this test was performed during cold shutdown conditions the Technical Specifications are ~ot affected. Therefore the margin of safety as defined in the basis for any Technical Specification is not reduced.
Special Test T-272 This Special Test covered vibration testing of the service water pumps to determine cause of high vibration levels.
Safety Analysis Summary The probability or consequences of an accident previously evaluated in the FSAR will not be increased by this test. The Technical Specifications permit re-moving one pump for test purposes; and was only be in this condition for a very short time.
It is the only piece of ESS equipment which was permitted to be removed.
No more than one pump is to be throttled.
The probability or consequences of a malfunction of equipment important to safety as previously evaluated in the FSAR is not increased. There was no affect on any other equipment as two other service water pumps were operating as required and adequate service water flow.was provided.
The possibility of an accident or malfunction of a different type previously analyzed in the FSAR was not created.
The margin of safety as defined in the basis for any Technical Specifications was not reduced since only one pump was tested at a time wQ.ich is permitted in the Technical Specifications.
,Special Test T-279 The purpose of this Special Test procedure is to obtain performance data on the High Pressure Safety Injection Pumps.
Safety Analysis Summary The probability or the consequences of an accident previously evaluated in the FSAR was not increased because of this procedure.
The probability or MI0189-018A-TC07 31
conquences of a malfunction of equipment important.to safety was not increased since the inoperable pump can readily be made available.
The possibility of an accident or malfunction of a different type than any previously evaluated in the FSAR was not created.
Operation within Technical Specification limitations were adhered to, therefore the margin of safety as defined in the basis for any Technical Specification was not reduced
- MI0189-0l8A-TC07 32
OPEN FACILITY CHANGES AND SPECIFICATION CHANGES INITIATED IN 1988 REPORTABLE ON THE ANNUAL REPORT NOT DECLARED OPERABLE OR CLOSED OUT MI0189-018A-TC07 33
FC-790 This modification covers the replacement of the Main Generator Voltage Regu-lator.
The difference between the old and new regulators is the method in which turbine assisted PCP coastdown is terminated.
The old regulator utilized a relay which actuated at 80% of synchronous speed whereas the new regulator uses a fixed timer.
Safety Analysis Summary The change in method of turbine-assisted coastdown of primary coolant pump motors from a frequency sensitive relay to a fixed timer with a setting of la seconds will not impact any existing plant safety analyses or design basis.
This 10 second value was picked to assure that the point of Minimum Departure From Nuclear Boiling Ratio (MDNBR) has passed for the loss of flow transients.
With the MDNBR point passed, any accident falls inside the bounds of the existing accident/safety analyses.
The probability of occurrence and/or consequences of accidents different than those previously evaluated in the FSAR will not be increased for the following reasons:
- 1.
The new voltage regulator will be more reliable than the one it replaced *
- 2.
The fixed timer relay will be inherently more reliable, precise, and accurate than the present voltage sensitive relay monitoring voltage regulator bias supply output.
The new relay will ensure that coastdown is terminated at 10 seconds (timing of the present coastdown feature is dependent upon a number of variable combinations.)
The margin of safety as defined in the basis for any Technical Specification is not reduced by this modification.
FC-809 This Facility Change provides for Variable Setpoint Low Temperature Overpres-surization Protection (VLTOP) by adding a microprocessor for each channel to the Low Temperature Overpressurization System (LTOP).
Safety Analysis Summary This Facility Change will replace the existing LTOP control scheme which features only fixed PORV actuation setpoint capacity.
The new scheme will feature a micro-processor unit capable of providing a PORV actuation setpoint which is automatically varied as a function of continuously monitored PCS pressure and temperature conditions. Additional operator interfaces (alarms, meters and switches) will also be installed.
The purpose of LTOP is to protect the Primary Coolant System (PCS) (including the reactor vessel) from pressure transients within the PCS which may occur MI0189-018A-TC07 34
while the PCS is operated at low temperatures.
During such conditions, the LTOP system will automatically act to prevent these transients from exceeding the Technical Specifications limits as required by 10CFRSO Appendix G, thereby protecting ferritic materials of the Primary Coolant System.
The LTOP system will act to prevent overpressurization of the Shutdown Cooling System whenever this system is not isolated from the Primary Coolant System.
The probability of an accident previously evaluated in the FSAR will not be increased because:
- 1.
The new design will comply with standard required for design materials and construction.
- 2.
Two redundant and independent channels of LTOP (variables) will be main-tained, each capable of protecting the PCS (including the Reactor Vessel) and the Shutdown Cooling System.
- 3.
The VLTOP microprocessors are programmed such that the variables set-point generated ensure that the tech spec limits as required by 10CFRSO Appendix G are not exceeded, thereby protecting the PCS.
The micro-processors are verified and validated to ensure that the expected output is achieved for all various input combinations and ranges.
- 4.
Each microprocessor (one/channel) provides a contact alarm output in the case of Central Processing Unit (CPU) failure which are wired to a control room annunciator.
The "CUP Fail" annunciation is received on loss of power to the CPU, software stall, or out of range pressure or temperature input signal.
Loss of power to the microprocessors is considered highly unlikely since each is powered from its own independent preferred AC supply.
S.
Protection of the.Shutdown Cooling System (SDC) is ensured by use of the VLTOP under administrative controls.
The procedural controls along with the VLTOP Shutdown Cooling mode switches ensure that the VLTOP is switched only at the predetermined, acceptable point in time.
- 6.
The VLTOP microprocessors receive PCS pressure and temperature input from existing Class IE instrument loop.
Instrument inaccuracy is taken into account in developing the VLTOP microprocessor PORV actuation setpoint curve.
Because of the above, the probability of an accident previously evaluated in the FSAR is not increased.
The consequences of an accident previously evaluated in the FSAR is not increased.
Installation of a VLTOP scheme to replace the existing fixed setpoint scheme has no impact on previously evaluated consequences.
The function of the new VLTOP system are identical to that of the existing system.
The probability of malfunctions of equipment important to safety is not in-creased as a result of this modification.
FSAR design criteria and modifi-cation ~ontrols are adhered to to ensure that a reliable LTOP function is provided and only acceptable impact on interfacing systems/equipment results.
MI0189-018A-TC07 35
Reliability of the LTOP control is maintained.
There will be no unacceptable electrical interfaces. The VLTOP hardware is mounted to ensure that the equipment will remain secured during a seismic-event.
This modification has no impact on the consequences of a malfunction of equip-ment important to safety.
The VLTOP is designed such that no single failure in either VLTOP channel would render the VLTOP function incapable of being per-formed.
The intent of VLTOP is not to mitigate accident consequences.
VLTOP is designed with the intent to prevent overpressurization accidents.
This modification does not create the possibility of an accident different than any type previously evaluated in the FSAR.
A highly reliable LTOP safety function is provided which is free of the effect of a single failure.
The VLTOP systems are properly isolated from Non-Class IE systems and equipment.
The possibility of a malfunction of a different type than any previously evaluated in the FSAR is not created because VLTOP acts to maintain the PCS from exceeding pressure/temperature limits; it acts to maintain the in-service SDC system operating pressure below its design pressure, and a VLTOP micro-*
processor failure does not cause the PORV to open. Also, a failed SDC mode switch will be immediately brought to the attention of the operator.
This modification does not involve a reduction in any margin of safety since it does not result in changing the allowable stress.
The VLTOP PORV actuation fixed setpoint is maintained identical to that currently employed by the LTOP for the SDC system protection.
FC-813 This modification covers the installation of permanent pressure gauges on charging pump accumulator's bladders.
The gauges will provide convenient bladder pressure indication and an air valve connection for charging or def lat-ing the bladder.
The objective of this Facility Change is to allow more frequent bladder pressure verification. Presently, a two month periodic verification is difficult to implement.
This modification will allow Opera-tions personnel to record bladder pressures on a bi-weekly interval. The complexity of the pressure verifications is reduced and any LCO time periods entered wouid be at low risk to continued plant operation.
Safety Analysis Summary The installation of the pressure gauges will not increase the probability or the consequences of an accident previously evaluated in the FSAR, will not increase the probability or consequences of a malfunction of equipment impor-tant to safety as previously evaluated in the FSAR, and will not create the possibility of a malfunction of a different type than any previously evaluated in the FSAR.
No different type of malfunction is created for the associated equipment.
The modification does not.reduce any margin of safety defined in the basis for any Technical Specifications.
MI0189-018A-TC07 36
FC-828 This Facility Change covers the addition of resin transfer and dewatering lines to the Track Alley, to eliminate running hoses from T-100 to shipping casks in the track alley and a hose used at the bottom of the cask to draw water from it.
Safety Analysis Summary The resin transfer system is considered a non-safety related system.
This modification decreases the length of hoses used to perform resin transfer.
The probability of an accident, or the consequences of an accident previously evaluated in the FSAR is not increased.
The probability or consequences of a malfunction of equipment important to safety is not increased, and the possi-bility of an accident or malfunction of a different type than any previously evaluated in the FSAR is not created.
The margin of safety as defined in the basis for any Technical Specification is not reduced.
SC-88-087 This Specification Change covers the replacement of area radiation monitors for Containment Air Room and the Personnel Air Lock, which were out of date and failure prone.
The new monitors operate digitally and more reliably.
Both monitors function will remain unchanged.
The old system functioned in an analog manner.
Safety Analysis Summary The replacement of the above monitors improves the reliability and allows the Personnel Air Lock monitors to be used in the future as a backup to the Con-tainment High Range Monitors.
No previously evaluated accident can be caused or affected by this replacement.
This replacement causes the area monitors to operate more reliably, therefore their ability to detect radiation increases is improved and the consequences of an accident would not be increased.
The probability of a malfunction of equipment important to safety is reduced.
The drift from calibrated values is greatly reduced because the new monitors function digitally. Malfunction of the new monitors is displayed on the readout because the systems perform self diagnostics and display error codes if a problem exists. Old area monitors employed a remote radiation check source while the new monitors utilize an electronic check source by pulsing the high voltage to the detector.
Use of the electronic check source and scheduled calibration continues to ensure that the area monitor is properly operating.
No other equipment important to safety is actuated or affected by thearea monitors.
The monitors will continue to perform the same function as in the past.
No accident of a different type than any previously evaluated in the FSAR is caused by this replacement.
Ho possibility of a nialfunction of a different type than any previously evaluated in the FSAR is created.
MI0189-018A-TC07 37
The margin of safety as defined in the basis for any Technical Specification is not reduced.
SC-88-351 This Specification Change covers the modification of 3 hangers on the eve piping.
The hangers were designed to a heavier construction to support the piping system when it discharges to the Quench Tank.
SAFETY ANALYSIS
SUMMARY
The probability of an accident or the consequences of an accident are not increased because of this modification. The hangers will withstand the service
-conditions presently being experienced within the piping system.
The probability of malfunction or the consequences of a malfunction of equip- -
ment as previously analyzed in the FSAR is not increased.
The possibility of an accident or a malfunction of a different type than any previously evaluated in the FSAR is not created, and the margin of safety as defined in the basis for.any Technical Specification is not reduced by this modification.
HI0189-018A-TC07 38
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