ML18047A554
| ML18047A554 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/30/1982 |
| From: | Dewitt R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML18047A553 | List: |
| References | |
| NUDOCS 8209030268 | |
| Download: ML18047A554 (6) | |
Text
- CONSUMERS POWER COMPANY Docket 50-255 Request for Change to the Technical Specifications License DPR-20 For the reasons hereinafter set forth, it is requested that the Technical Specifications contained in the Provisional Operating License DPR-20, Docket 50-255, issued to Consumers Power Company on October 16, 1972, for the Palisades Plant be changed as described in Section I below:
I.
CHANGES A.
Add Section 3.6.4:
"Two independent containment hydrogen recombiners shall be operable when the reactor is at power or at hot standby.
With one hydrogen recombiner system inoperable, restore the inoperable system to operable status within 30 days or be in at least hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />."
B.
Revise Section 3.8.4 to read as follows:
"The ventilation system and charcoal filter in the fuel storage building shall be operating whenever irradiated fuel which has decayed less than 30 days is being handled by either of the following operations:
- a.
Refueling operation with the equipment door open, or
- b.
Fuel handling in the fuel storage building.
If both fans are unavailable, any fuel in transition or crane operation shall be completed and further fuel movements or crane operations with loads _in excess of 1300 pounds over the spent fuel storage pool shall be'terminated until one fan is returned to service."
- c.
Revise Section 3.8, Basis, last paragraph, first sentence to read as follows:
"The charcoal filter installed in the fuel handling building exhaust will handle the full (ap~roximately 10,000) cfm capa:ity(4)"
of the normal ventilation flow with both exhaust fans operating.
D.
Revise Section 3.8, Basis, last paragraph, starting with the fifth sentence, to read as follows:
"The efficiency of the installed charcoal filters *is at least 90% for inorganic species and 70% for organic species with rated flows. ( 5)
The off-site thyroid dose in the fuel handling accidents analyzed will be less than 15 Rem using these efficiencies should an irradiated fuel bundle be damaged in handling.(5)
The fuel handling accident analysis assures that
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DMCrutchfield, Chief Palisades Plant Request for Change to the Technical Specifications the charcoal adsorbers will perform to remove a minimum of 2
70% and 90% (organic and inorganic, respectively) iodine activity.
Following a period of 30 days, the I-131 will have decayed by a factor of 10 and adsorption by charcoal will no longer be required.
Valve alignment check sheets are completed to protect against sources of unborated water or draining of the system."
E.
Replace Section 3.8, References, Item 5, with:
"(5)
FSAR, Appendix J" F.
Change Section 3.13, Applicability, to read:
"Applies to the use of cranes over the primary coolant system and the spent fuel storage pool. "
G.
Add item "c" to Section 3.13, Specifications, as follows:
"c.
The fuel storage building ventilation shall be operating and discharging through the HEPA and charcoal adsorbers during crane operation with loads in. excess of 1300 pounds over the fuel storage pool when irradiated fuel which has decayed less than 30 days is in the spent fuel storage pool.**
H, Change heading of Section 3.14 to read:
"Control Room Ventilation" I.
Change Section 3.14, Applicability, to read:
"This specification applies to the control room ventilation system."
J.
Change Section 3.14, Objective, to read:
"The operability of the control room ventilation system ensures that (1) the ambient air temperature d.oes not exceed the allowable temperature for continuous duty rating for the equipment and instrumentation cooled by this system, and (2) the control room.
will remain habitable for Operations personnel during and follow-ing all credible accidents."
I DMCrutchfield, Chief Palisades Plant Request for Change to the Technical Specifications K.
Change Section 3.14, Specifications, to read:
"a.
If the control room air temperature reaches 120°F immedia.te action shall be taken to reduce this temperature or to place the reactor in a hot shutdown condition.
- b.
The control room ventilation system, consisting of two fans and a filter system, shall be operable.
With both fans in-operable or the filter system inoperable, restore the system to operable status within 3-1/2 days or be in cold shutdown within the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
11
- 1.
Add the following sentences to Section 3.14, Basis:
"The control room ventilation systems are independent except for the charcoal filter and associated equipment.
The charcoal filter ~ystem is designed to provide filtered makeup air to the control room following a design base accident and is not used
- during normal operation."
M.
Change the Table of Contents for Section 3.14 to read:
Section II 3.14 Description Control Room Ventilation
- a.
Delete Item 14 of Table 4.1.3 in its entirety.
O.
Change Section 4.2, Specifications, as follows:
Page 3-70" "Equipment and sampling tests shall be conducted as specified in Tables 4.2.1, 4.2.2 and 4.2.3."
P.
Change the first sentence in the Basis of Section 4.2 to read as follows:
"The equipment testing and system sampling frequency specified in Tables 4.2.1, 4.2.2, and 4.2.3 are considered adequate, based upon experience, to maintain the status of the equipment and systems so as to assure safe operation."
Q.
Delete Item 11 of Table 4.2.2 in its entirety.
"Charcoal and High Efficiency filters II 3
R.
Change Items 12 and 13 of Table 4.2.2 to Items 11 and 12 respectively.
DMCrutchfield, Chief Palisades Plant Request for Change to the Technical Specification I.
CHANGES (Continued)
- s.
Change Sections 11.b and 12.c to read as follows:
"At least once per refueling cycle..... "
T.
Add new Table 4.2.3.
NOTE:
Revised Technical Specification pages are attached.
Proposed changes are shown by a vertical line in the right-hand margin.
II.
DISCUSSI011T The above proposed Technical Specifications changes are required in order to achieve closer conformance to the Standard Technical Specifications.
The following describes the proposed changes:
Item A This Technical Specifications change was submitted to the NRC on May 14, 1980, in order to conform to guidance provided in NUREG-0212 (CE Standard Technical Specifications).
Items B, C, D, E and G These Technical Specifications changes were submitted to the NRC on March. 6, l1T5 and February 25, 1976.
The fuel handling accident analysis (
1 assumes that the charcoal adsorber will perform to remove 70% and 90% (organic and in9rganic, respectively) of radioactive iodine and demonstrates that release to the atmosphere is within acceptable limits.
Following a decay period of 30 days, the iodine activity levels will be more than a factor of 10 below those assumed in the analysis and use of the charcoal adsorber will not be required to maintain acceptable release levels.
Calculations based on Regulatory Gujde 1.25 (3/23/72) show that the site boundary thyroid inhalation dose resulting from a postulated fuel handling accident will be less than 15 Rem.
The addition to Section 3.8.1 Specifications as proposed by Consumers Power Company letter dated March 6, 1975 has been incorporated into Section
- 3. 8. 4, Specifications.
Item B includes those parts of the applicability 4
and action requirements not already existing in the Technical Specifications.
The capacity of the fuel handling system has been changed to approximately 10,000 cfm in agreement with measured values and the reference to "two" installed charcoal filters has been deleted since there are twenty-seven.(27) charcoal trays in one unit.
(1)
See Amendment No 21, New Appendix J to the FSAR titled "Evaluation of Postulated Accidents" and Transmitted by letters dated August 9, 1974 and March 11, 1975
I DMCrutchfield, Chief Palisades Plant Request for Change to Technical Specifications II.
DISCUSSION (Continued)
Item F This item corrects a previous typographical error changing the last word from "fuel" to "pool".
Items H, I, J, K, Land M These Technical Specifications changes were submitted to the NRC on June 18, 1975.
These proposed changes provide limiting conditions 5
for operation related to the operability of the control room ventilation system (safeguards mode), or the actions to be taken in the event the system becomes inoperable.
Item K allows the control room ventilation system to be inoperable for a period of 3 ~ days before cold shutdown must be initiated.
This period has been reduced from the originally requested 7 days because the control room system does not have redundant filter systems and doses to the control room operators, based upon the present control room ventilation system design, results in GDC 19 being exceeded.
Item N This requirement has been incorporated into Table 4.2.3 as items C.2 and C.3.
Items 0 and P These items add references to the new Table 4.2.3.
Items Q, R and S Item Q *deletes the old filter testing requirement and was submitted to the NRC'on March 6~ 1975.
Item i:r This Technical Specification change was originally submitted to the NRC on March 6, 1975.
By telephone conference call on March 17, 1982, between NRC staff members and representatives of Consumers Power Company, questions and coillirients were posed concerning Table 4.2.3.
Subsequent telephone conversations with Mr Jack Hayes of your staff has resolved all remaining questions and disagreements.
This submittal includes the revised Table 4.2.3 which incorporates most of the additions and modifications as agreed upon by Consumers Power Company and the NRC.
The only major change made subsequently to the telephone conversations with the NRC is the deletion of the surveillance test for control room air temperature.
This requirement was deemed unnecessary due to the fact that it would be obvious to the Control Room personnel if air temperature approached 120 degrees.
Thus, documentation of Control Room air temperature.on a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> basis to verify filter operation is unwarranted.
DMCrutchfield, Chief Palisades Plant Request for Change to Technical Specifications II. DISCUSSION (Continued) 6 Table 4.2.3 includes the testing requirements for HEPA Filters and Charcoal Adsorber systems for both the Control Room and Fuel Storage Area.
The containment hydrogen purge system has been excluded since purging is no longer an acceptable method to eliminate hydrogen buildup and thus, credit is taken only for the recombi*ners in accident analysis.
Item A requires that flow be established periodically through HEPA Filters and Charcoal Adsorbers in order to reduce moisture buildup.
Flow is required for 15 minutes instead of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> as originally proposed because there are no heaters in the system.
Subitem B.l requires a methyl iodide removal efficiency of~ 94% instead of 99%.
NRC letter dated February 11, 1982, stated that based on NRC review of the Spent Fuel Pool Area Ventilation System and Consumers Power Company's fuel handling accident analysis, it was determined that the system did.not perform functions important to safety, as defined in Regulatory Guide 1.105.
Therefore, a methyl iodide limit of 94% is acceptable.
The rated flow rate for the Control Room Ventilation System was verified by Special Test Procedure T-133 to be 765 cfm.
The test, T-133, was written to document system performance, and to establish baseline data for the Control Room ventilation system.
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.
CON~°!COOANY BY lJ:O_ ~rz-,..=.-..1t6+---
R B DeWitt, Vice President Nuclear Operations Sworn and subscribed to before me this 3oth day of August
, 1982.
Helen I Dempski, Notary Public Jackson Coun_ty, Michigan c
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My c9inmission -expires December 14, 1983.
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