ML18051B014
| ML18051B014 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/31/1984 |
| From: | Vandewalle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML18051B015 | List: |
| References | |
| RTR-NUREG-0472, RTR-NUREG-472 NUDOCS 8408070431 | |
| Download: ML18051B014 (6) | |
Text
consumers Power company General Offices: 1945 West Parnell Road, Jackson, Ml 49201 * (517) 788-0550 July 31, 1984 Dennis M Crutchfield, Chief Operating Reactor Branch No 5 Nuclear Reactor Regulation US Nuclea~ Regul~tory Commission Washington, DC 20555
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l DOCKET 5*0-255 -, LICENSE DPR PALISADES PLANT - RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS (RETS),
OFFSITE DOSE CALCULATION MANUAL (ODCM) AND PROCESS CONTROL PROGRAM (PCP)
Attached are three (3) signed originals and thirty seven (37) conformed copies of a Request for Change to the Palisades Technical Specifications. This request is in response to NRC letter dated October 31, 1983 entitled "Radiological Effluent Technical Specifications" (RETS) that transmitted Draft "7" of NUREG-0472 Revision 3 "Standard Radiological Effluent Technical Specifications for Pressurized Water Reactors, September 1982".
In this letter the NRC requested that Consumers Power Company develop our final RETS submission using this guidance and also requested we finalize our schedule for our submittal.
In a letter dated December 5, 1983, Consumers Power Company committed to submit our final RETS and ODCM by July 31, 1984.
This submittal completes that commitment.
Our PCP is also included in this submittal.
The development of RETS has been an arduous task, complicated by many revisions to NRC guidance since its inception in June of 1975 and the fact that the Palisades Plant does not have standard technical specifications.
At various times, Consumers Power Company representatives have met with NRC staff and contractors to discuss our proposals.
At our recent April 5 and 6, 1984 meeting however, Consumers Power Company and NRC representatives negotiated what is jointly believed to be an acceptable and final RETS.
The agreements and technical positions discussed during that meeting are reflected in our enclosed submittal.
As directed by NRC staff at that meeting, negotiated resolutions to problem issues which required some deviation from NUREG-0472 guidance are summarized and explained below. Additionally, the very nature of this submittal poses certain logistical problems.
Entire sections of the existing technical specifications must be deleted; certain technical specifi-cation change requests pending NRC approval must be withdrawn or otherwise modified; and changes in 10 CFR reporting requirements negate both portions of our existing technical specifications and the NUREG-0472 guidance.
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DMCrutchfield, Chief Palisades Plant RETS, ODCM AND PCP July 3i~ 1984
- For clarity, each of these.sections has been addressed in separate detail:
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effects* of changes to 10 CFR reporting require~ents NRC accepted deviations fro)ll NUREG-0472 guidance modifications to technical specification change requ,ests pending NRC action/approval existing technical specifications sections to be deleted EFFECTS OF CHANGES TO 10 CFR REPORTING REQUIREMENTS A new Section 50.73 of Title 10 of the Code of Federal Regulat,ions was recently added which provides for a revised Licensee Event Report (LER)
System.
At NRC request, conforming changes to the Paiisades technical spedfications were made in our submittal.dated July 30, 1984.
Our RETS submittal has.been prepared to conform with these revised reporting ~equire ments and.our proposed technical specification change of July 30, 1984, and
.contains no reference to Reportable Occurrences *. Additionally, our RETS submi.ttal.has deleted references to Licensee Event Reports where Special Reports are required in keeping with the directives of Generic Letter 83-43.
NRC ACCEPTED DEVIATIONS *FROM NuREG-0472* GUIDANCE.*
.Fe55 Analysis Liquid waste anal)'sis.for Fe55 is not required per our April 5 and 6 meeting
- with NRC staff.. A previous Consumers. Power Company* submittal dated *June 7-,
. 1982 provides the justification for deietion of this analysis.
A copy of this letter and suppor;ing appendices is found in Attachment A to this letter.
Tritium Gaseo.us tritium analysis requirements have been deleted from our proposed RETS because tritium has such a smail dose impact on the public *. The major contributor to tritium effluents are* evaporation from the fuel pool and refueling cavity.
Accountability of tritium by conservative evaporation rate calculations indicates effluents* are less than 10 curies annually.
Util'izing
.the GASPAR c.ode with annual average meteorology indicates a tritium dose consequence of less th.an 1. 3E-03 mRem annually..
- Waste Gas Holdup System - Explosive Gas Mixtures:
NUREG-0472 contains suggested technical specifications for explosive gas mixtures in the gaseous radwaste treatment system waste gas holdup tanks.
The Palisades plant has a 13 year performance history routinely operating with mixtures in the explosive range.
This successful operating history is attributed to.the current design and maintenance program which utilizes oil reservoir c'ooling, diaphragm valves, grounded tanks, etc.
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DMCrutchfield, Chief Palisades Plant RETS, ODCM AND PCP July 31, 1984 3
Ignition of the gaseous.mixture inside of the waste gas system is. highly unlikely because the tanks (and therefore the system) are grounded (static charge buildup due to flowing gases is discharged to the tank wall and then to ground).
The gas flow rate is low, the diaphragm of the compressor is cooled by the oil reservoir in which it moves, and the valves are ethylene-propylene diaphragm valves (so there is no metal-to-metal contact).
These items all reduce the probability of explosive mixture ignition. Because of the above, the probability of ignition is *small and therefore no further hydrogen monitoring equipment is required.
Liquid and Gaseous Effluent Monitoring Liquid and Gaseous Effluent Monitoring Instrumentation Surveillance Table requirements have been modified in our proposed RETS because the installed instrumentation does not have a trip function on circuit failure.
All monitors have high.alarm and circuit failure annunciation.
None of the
.instruments have a trip or alarm function for downscale failures or controls not set in the operate mode.
Purge of Containment During Power Operation A technical specification change request that prohibits purge of*containment during power operation has been proposed in our letter ~ated June 13, 1984.
This technical specification chang*e eliminates the n~ed for continu9us con.tainment sampling requirements.
Iodine Monitoring Palisades utilizes a continuously operating iodine monitor.
Accoi::dingly, special sampling requirements are not required unless this instrument is inoperable.
The RETS proposal has bee*n developed to reflect these* modes of operation *
. Deletion of Component Cooling Water Monitor NUREG-0472 guidance for component cooling water instrumentation does not apply to the Palisades Plant because it is a closed loop system that does not discharge to the environment.
Liquid Radwaste System Effluent Storage Tank Drains Radwaste system effluent storage tanks T90 and T91 have overflows to the liquid radwaste system.
Accordingly, tank level indicating devices have been omitted from the Radiological Liquid Effluent Monitoring Instrumentation.
Meteorological Data In keeping with NUREG-0472 guidance, the licensee has elected to retain meteorological data within the general office radiological files.
This data will be maintained for NRC review by the Radiological Services Department.
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4 MODIFICATIONS TO TECHNICAL SPECIFICATION CHANGE REQUESTS PENDING NRC APPROVAL ACTION
- 1.
Modification of Proposed Technical Specification Request On Operability An August 21, 1980 Consumers Power Company submittal proposed adding Sections 3.0.1, *3.0.2> 3.0.3, 3.0.4, and 3.0.5 (Limiting Conditions of Operation - Applicability) to the Palisades Technical Specifications.
Sections 3.0.1, 3.0.2, 3;0.3 and 3.0.4 of that submittal are hereby withdrawn and replaced with the enclosed Sections 3.0.1; 3~0.2., J.0.3, and 3.0.4 as developed per NUµG-0472 and staff guidance at our April 5 and 6,. 1984 meeting.
Section 3.0.5 and the change in* definition. of "operable" as proposed in.
- oµr August 21, 1980 submittal are not affected by this* proposal.
- 2.
Modification of Proposed Technical Specification Request on NUREG-0737 Requirements - Table 3;17.4 In a letter dated November 5, 1982, Conswilers Power Company submitted a replacement Table 3.17.4 entitled "Accident Monitoring Instrumentation" that incorporated some of the requirements of NUREG-0737.* Consumers Power Company has determined that a~l process monitor.requirements should be located within one table within each section of the Technical Specifi-cations to facilitate plant *operations.
Accordingly, Consumers Power Company is hereby withdrawing item 12 "Stack Effluent Noble Gas Monitor," item 13 "Stack Effluent Particulate Monitor" and item. 14 "Main Steam Safety and Dump Valve Discharge Monit~r" and attendant notes,(g), * (h), and (i) from the November 5, 1982 proposed Table 3.17.4.
This information is now located. in proposed RETS Table 3.24-2.
The* action requirements for these three monitors that were previously delineated by note (e) of the November 5, 1982.proposed Table 3.17.4 have been revised.in our prop9sed RETS Table 3.24-2.
This revision is to reflect Generic Letter 83-37 guidance,. with the-exception bring the Special Reporting requirement reflects 30 days rather than 14 days for reporting consistency.
- 3.
Modification of Proposed Technical Specification Request on NUREG-0737 Requirements - Table 4.1.3 In a letter dated November 5, 1982, Consumers Power Company submitted a replacement Table 4.1.3 "Minimum Frequencies for Checks, Calibrations, and Testing of Miscellaneous Instrumentation and Controls" that incorpor-ated some of the. requirements of NUREG-0737.
In that proposed technical specification change, information concerning area and process monitors was separated, with expanded information on area monitors contained in item 4 of Table 4.1.3 and process monitors contained in item 21 of that table.
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DMCrutchfield,.Chief Palisades Plant RETS, ODCM AND PCP July 31, 1984 5
In keeping with NUREG-0472 guidance, all process monitor surveillance requirements previously contained in Table 4.1.3 are now located in proposed Tables.4.24-1 "Radioactive Liquid Effluent Monitoring Instrumen-tation Surveillance Requirements" and*4.24-2 "Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements".
Accordingly, Consumers Power Company is hereby withdrawing item 21 "Process Monitors" of Table 4.1.3 from our proposed November 5, 1982 technical specification change request and our May 5, 1983 revision to same. Our November 5, 1982 proposed technical change concerning item 4 "Area Monitors" and May 5, 1983 revision to same are not affected by this submittal.
EXISTING TECHNICAL SPECIFICATIONS TO BE DELETED Section 3.9 Section 3.9 "Effluent Release" of the.existing Technical Specifications is to be deleted in its entirety.
The information contained in Section 3.9 has been expanded, revised and reformatted in accordan~e wit.h NUREG-0472 and sta:ff guidance and is now.found in a new proposed Section 3.24 entitled "Radio-logical Effluent Releases".
Section 4.11 Section 4.11."Environmental Monitoring Program" is to be deleted in its entirety.
The information formerly con~ained in Section 4.11 has been reformatted and revise;d in accordance with.NUREG.:..0472 and staff guidance and is now located in a new proposed Section 4.11 entitled "Radiological Environ-mental Monitoring".
Special Technical Spec*ifications Pursuant to Agreement Pursuant to an agreement dated March "12, 1971 between Consumers Power Company and the Michigan Steelhead and Salmon.Fisherman's Association, a Section S entitled "Special Technical Specifications Pursuant to Agreement" was added to the Palisades License DPR-20.
This agreement carried an automatic termination clause based upon initial successful operation requirements of the modified
- condenser cooling arid liquid radwaste systems..
In a letter dated July 3, 1980.
Consumers Power Company submitted a proposed*Technical Specification change request to delete this entire Section S based.upon the conditions of the agreement having been met.
On January 22, 1981 Amendment No 63 was issued 'that deleted all.subsections of S with the exception of subsection S-2 on radiological effluents and monitoring.
In that letter, the NRC indicated the deletion of $-2 would be further considered during the reevaluation of our program to implement 10 CFR Part 50 Appendix I~
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DMCrutchfield, Chief Palisades Plant RETS, ODCM AN1) PCP July 31, 1984 6
Consumers Power Company believes that this submittal of our proposed RETS fully meets the requirements of the Commission in this matter and is again requesting the deletion of S-2.
Without deletion of S-2, the propbsed RETS.
cannot be implemented due to lack of compatibility in format and scope.
PREVIOUS RETS, ODC:t-! AND PCP SUBMITTALS AND RESPONSES TO NRC QUESTIONS
.In letters dated June 4, 1976 and March 12, 1979, Consumers Power Company submitted proposed Radiological Effluent Technical Specifications in response to the requirements of Appendix I to Title 10 CFR Part 50.
These proposed Technical Specifications Change Requests are hereby withdrawn.
Consumers Power Company also remitted a Clas~ III change fee of $4,000 for the Palisades plant in our letter of December 4, 1979.
This fee should Qe applied towards review of the enclosed proposed RETS.
Additionally draft ODCM's and PCP's submitted prior to this date are hereby superseded by the enclosed ODCM and PCP.
RETS IMPLEMENTATION DATE In our meeting of April 5 and 6, 1984, the NRC Technical Reviewer requested Consumers Power Company identify an implementation date for the RETS in in our submittal.
The implementation date is conting~nt upon the date when the NRC will approve our proposed RETS and subsequent changes resulting from NRC review, if any.
Based on our April meeting with NRC staff, we understand that our July 31, 1984 submittal should result in a staff SER by mid-September and issuance of the license amendment by early October. If the NRC is able to meet this rigorous schedule, Consumers Power Company is prepared to implement
- our RETS by January 1, 1985.
Administrative expediency req~i~es a minimum of
.75 days from the date of issuance.of the license amendment a:nd that the
- implementation dates fall on the first day of either Ja~uary or July. Your expeditious handling o~ this request is appreciated.
Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachments OC0784-0001-NL02