ML18047A416

Application to Amend License DPR-20,changing Tech Specs Re Operation W/Inoperable Reactor Protection Sys & ESF Actuation Sys Channel

ML18047A416
Person / Time
Site:	Palisades
Issue date:	06/25/1982
From:	Dewitt R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML18047A415	List: ML18047A414 ML18047A416 ML18047A417
References
NUDOCS 8207070446
Download: ML18047A416 (4)

Text

CONSUMERS POWER COMPANY Palisades Plant REQUEST FOR CHANGE TO THE TECHNICAL SPECIFICATIONS Docket 50-255 License DPR-20 For the reasons hereinafter set forth, it is req_uested that the Technical Specifications contained in the Provisional Operating License DPR-20, Docket 50-255, issued to Consumers Power Company on October 16, 1972, for the Palisades Plant be changed as described in Section I below:

I. CHANGES A. Replace Section 3,17.2 with the following:

"As a minimum, the Reactor Protection System instrumentation channels and bypasses shall be OPERABLE as defined in Table 3.17.1."

B. Add Section 3.17.3:

"As a minimum, the Engineered Safety Features instrumentation channels and bypasses shall be OPERABLE as defined in Table 3,17.2."

C. Add Section 3.17.4:

"As a minimum, the channels and bypasses in "other Safety Feature Functions Instrumentation" shall be OPERABLE as defined in Table 3.17. 3."

D. Add Section 3.17.5:

"In the event that the number of channels of a particular system listed in Table 3,17.4 "Accident Monitoring Instrumentation" falls below the limits given in the columns entitled "Minimum Operable Channels" or "Minimum Degree of Redundancy", except as conditioned by the column entitled "Permissible Bypass Conditions", either restore the number of operable channels to the "Minimum Operable Channels" within seven days, or place the reactor in hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and cold shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

E. Revise Section 3.17, Basis, paragraph three, to read as follows:

"When one of the four channels is taken out of service for maintanance, the protective system logic can be changed to a two-out-of-three coincidence by bypassing the removed channel for a limited time."

F. Delete the last two sentences of Section 3.17, Basis, paragraph four.

G. Revise the last line of Sect.ion 3.17, Basis, paragraph six, to read as follows:

" .with footnote (b) of Table 3.17,3,"

8207070446* 820625 PDR ADOCK 05000255 P Pn~

.e DMCrutchfield, Chief 2 Palisades Plant Request for Change to Technical Specification June 25, 1982 I. Changes (Continued)

H. Add the following paragraph to Section 3.17, Basis:

"Since the instr.umentation of Table 3 .17. 4 used for accident monitoring does not provide protective actions or initiate engineered safety features, their operability requirements are less restrictive thari for Tables 3.17.l, 3.17.2 and 3.17.3."

I. Replace Table 3.17.l with revised Table 3.17.1, "Reactor Protective Instrumentation."

J. Replace Table 3.17.2 with revised Table 3.17.2, "Engineered Safety Feature Actuation System Instrumentation."

K. Replace Table 3.17.3 with revised Table 3.17.3, "Other Safety Feature Functions Instrumentation."

L. Replace Table 3.17.4 with revised Table 3.17.4, "Accident Monitoring Instrumentation."

M. Add Items 19, 20 and 21 to Table 4.1.3 as follows:

"19. Containment Pressure a. Check s a. Comparison of Channels Wide Range b. Calibrate R b. Known Pressure Applied to Sensors

20. Containment Sump a. Check s a. Comparison of Channels Water Level Instrument b. Calibrate R b. Known Differential Pressure Applied to Sensors

21. Containment Floor a. Check S a. Comparison of Channels Water Level Instrument b. Calibrate R b. Know level Applied to Transducer" NOTE: Revised Technical Specification pages are attached. Proposed changes are shown by a vertical line in the right hand margin.

II. DISCUSSION The recommended Technical Specifications change, as prescribed by NRC letter dated April 16, 1981, is to allow a maximum of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of power operation with one channel of RPS and/or ESFAS in the "bypass" mode. In addition, the recommended changes provided for one channel to be placed in the "trip" mode indefinitely during which time a second channel could be placed in the "bypass" mode for a maximum of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

DMCrutchfield, Chief Palisades Plant Request for Change to Tech Specs

• 3 June 25, 1982 II. DISCUSSION (Continued)

Consumers Power Company acknowledges the requirement to establish a limit as to the length of time one channel of RPS and/or ESFAS can remain in the "bypass". mode. We consider, however, that a 48-hour limitation is unreasonable since it would prohibit most RPS and ESFAS failures from being effectively investigated and repaired according to responsible practices and procedures with the plant at power. As an example of a situation in which a 48-hour limitation would have a high probability of resulting in a needless plant shutdown, consider an instrumentation failure which could occur just prior to a weekend.

A 48-holir repair in this circumstance may not be feasible given a temporary unavailability of certain skilled staff personnel, specialized test instri..µnents or qualified replacement parts. Even if the failure was to occur early in the week, a 48-hour repair may be difficult.

Certain skilled personnel may be off site for a number of days and/or specific test instruments may be off site for a number of days while being repaired and/or calibrated. In addition, the procurement and quality control processing of safety-related replacement parts often requires a number of days to complete.

As a reasonable alternative, Consumers Power Company is proposing a seven day limitation in lieu of the 48-hour limit recently granted to the St Lucie Plant. It is our opinion that in most instances, seven days would provide a reasonable opportunity to accumlate the required manpower, tools and parts to effect quality repairs without needlessly jeopardizing plant availability nor the health and safety of the public. Consumers Power Company, however, does consider as as acceptable the 48-hour limitation for the manual RPS and ESFAS initiations and the 48-hour limitation for the situation in which one channel is placed in the "trip" mode indefinitely and a second channel is placed in the "bypass" mode.

Other specific changes to Tables 3.1[.l, 3.1[.2, 3.1[.3 and 3.1[.4 include:

(1) The action statements for Tables 3.1[.l and 3.1[.2 have excluded the requirement of placing an inoperable channel in trip or bypass within one hour. It is not possible to achieve the required action within one hour.

(2) The HPSI flow instruments in Table 3.1[.4 were deleted as they perform no post-accident safety-related function, and no credit is taken for these instruments in accident analysis.

DMCrutchfield, Chief 4 Palisades Plant Request for Tech Spec Change June 25, 1982

( 3.) The requirement in Table 3 .17 .1 and the Basis of Section 3 .17 to limit reactor power to less than 70% whenever two high power range channels are inoperable was deleted. The limits of Section 3.23.3 and surveillance requirements of 4.18 and 4.19 are adequate to prevent exceeding design peaking factors resulting from undetected flux tilts.

(4) The requirements related to primary and secondary dataloggers was changed to delete the requirement for the out-of-sequence monitor, as this is considered to be a convenience rather than an item required for safety. The action statement related to loss of rod*

insertion limit monitors was revised to permit continued operation for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, subject to conditions specified.

(5) The 15% setting for enabling the loss of load trip and disabling the start-up rate trip was changed to 15+ 2% to provide needed flexibility.

(6) The permissible bypass condition for containment high pressure channels during containment leak tests was deleted.

(7) The containment pressure and water level instrumentation has been added to Table 3,17.4. These proposed Technical Specifications changes are requested in order to provide a continuous indication of containment pressure and water level in the control room.~

III. CONCLUSION Based on the foregoing, both the Palisades Plant Review Committee and the Safety and Audit Review Board have reviewed these changes and find them acceptable.

CONSUMERS POWER COMPANY BY RB DeWitt, Vice President Ruclear Operations Sworn and subscribed to before me this 25th day of June, 1982.

Dempski, Notary ublic Jackson County, Michigan My cqmmission expires December 14, 1983.