ML18047A273
| ML18047A273 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/31/1982 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Walle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML17336A025 | List: |
| References | |
| TAC-7089, NUDOCS 8204130480 | |
| Download: ML18047A273 (3) | |
Text
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MAR 3 1 1982 Docket No. 50-255 Mr. David Vande Walle Nuclear Licensing Assistant Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201
Dear Mr. Vende Walle:
D)-STRIBUTI ON:
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ACRS-10 I&E Gray File PMKreutzer-3 RAClark EConner By letter dated July 27, 1981, you informed the staff that the informa-tion requested in our letter of April 16, 1981 on Reactor Protection System (RPS) and Engineered Safety Features Actuation System (E$FAS) logic would be provided by September 15, 1981. Since issuance of the April 1981 letter3 we have modified our position slightly.
Two options are provided for licensees to follow.
Option l would allow the bypass of an inoperable channel for a period not to exceed 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> at which time the inoperable channel must be placed in the trip mode.
Option 2 would allow the bypass of an inoperable.channel in accordance With the requirements delineated in the Technical Specifications (TS} Enclosure 1 Action Statement 2.
Option 2 is less restrictive than Option l.
Option l The original TS proposed by the staff for plants requesting to operate as a two-out-of-three system was to require that the inoperable channel be placed in the** tripped condition within one (l) hour. Subsequent to this requirement, 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> bypass was approved by the staff on various operating plants (Calvert Cliffs, St. Lucie 1, and Arkansas Nuclear One Unit 2) based on the staff's review of the RPS and ESFAS sensor channels for the adequacy of physical and electrical independence.
Based on all reviews of Combustion Engineering (CE} designed plants completed to date, we now conclude that there is no technkal or safety basis for limiting the bypass of a channel to one hour rather than 4B hours.
Permitting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> rather than l hour prior to placing an inoperable channel in trip may, in fact, be a benefit to plant safety by reducing the probability of inadvertent protection system actuations and by providing greater flexibility in performing maintenance and/or testing on an inoperable channel~
- s;e:l~ec'.titon of this option should result in application for TS in the form of Enclosure 3 to our letter of April 16, 1981.
OFFICE.........................................................................................................................................................................
SURNAME>..................................... : **********
( 82-04130480 820331
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. '=-FICIAL RECORD COPY USGP0:1981-335-960
" Option 2 If it can be verified that three protection system channels in two-out-of-three logic are sufficient to satisfy all protection system criteria, then one channel of a four channel system may be bypassed for a lengthy period of time with no de9radation to safety. Action Statement 2 of the Enclosure 1 TS pages {San Onofre - Unit 2) may be proposed in place of Action 2 of Enclosure 3 of our April 16, 1981 letter. Enclosure 2 delineates the criteria which must be satisfied to ensure that three channels are sufficient for plant protection. However, we believe that it is prudent that an inoperable channel be repaired and returned to service as quickly as practicable. Action Statement 2 of Enclosure 1 would allow the flexibility of continued plant operation with an inoper-able channel in bypass where it is not feasible to repair the channel (for example, if the failure is inside the containment in a location inaccessible during plant operation).
The model TS, however, do place responsibility on the licensee to repair the channel as quickly as possible and in any event during the first cold shutdown after the failure has occurred.
Option 1 may be implemented by a request from you without any further analyses or review of the protection system by either the staff or yourself. Option 2 should be implemented only after you have requested this option and have verified to the staff that you have reviewed the plant design and determined that it complies in all respects to the criteria delineated in Enclosure 2.
No review would be required by the staff unless a significant question arises related to your review.
Application for the Option 1 or Option 2 TS should be submitted any time within the next 6 months.
The issue should be resolved before startup
'from the subsequent scheduled refueling outage.
Enclosures:
As stated cc:
See next page Sincerely, Original signed by:
Dennis M. Crutchfield, Chief Operating Reactors Branch #5 Division of Licensing OFFICE. **~-~~~~r" SURNAME. ****r******************
/} h/ /82 DATE~ J****"::; ** *******:***
NRG FORM 318 (10-80) NRCM 0240 OFFICIAL RECORD COPY USGPO: 1981-335-960
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Mr. David J. Va~~eWa11e
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cc M. I. Miller, *Esquire Isham, Lincoln & Beale Suite 4200 One First National Plaza Chicago, Illinois. 60670
- Mr. Paul A. Perry, Secretary
- C*onsumers Power Company 212 West Michigan Avenue Jackson,_Mfchigan 49201
. Judd L. Bacon, Esquire Consumers Power Company 212 West Michigan Avenue Jackson, Mi chi ga.n 49201 CHERRY & FLYNN Suite 3700 Three First National Plaza Chicago, Illinois 60602 Ms. Mary P. Sinclair Great Lakes Energy Alliance 5711 Summerset Drive Midland, Michi~an 48640 Wi11iam.J*. Scafllon, Esquire
.2034 *.P au1 i ne Bou1 evard Ann Arbor, Michigan 48103 Township Supervisor Covert Townshi Route 1, Box 10 Van Buren County, Michigan 49043 Office of the Governor (2)*
Room* 1 -
C~pito1 Building Lansing, Michigan 48913 Palisades Plant ATTN:
Mr. Robert Montross Plant Manager Covert, Michigan 49043 U. S. Environmental Protection Agency Federal Activities Branch.
Region V Office ATTN:
Regional Radiation Repr~sentative 230 South Dearborn Street Chicago, ~llinois 60604 Charles Bechhoefer, Esq., Chairman Atomic Safety and Licensing Board Panel U. S~ Nuclear RegulatOry Commission*
Washington, D. C.
20555 Dr. George C. Anderson *.
Department of Oceanogra~hy University of Washington Seattle, Wa~hington 98195.
Dr. M. Stanley Livingston 1005 Calle Largo Santa Fe, New Mexico* 87501 Resident Inspector c/o U. S. NRC Palisades Plant Route 2, P. o. Box 155 Covert, Michigan 49043 James G. Keppler, Regional Administrator Nu cl ear Regulatory Commi ssi o.n, Region I II 799 Roosevelt Road Glen Ellyn, Illinois 60137