ML18051B332
| ML18051B332 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/01/1985 |
| From: | Johnson B CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8504040209 | |
| Download: ML18051B332 (18) | |
Text
consumers Power company General Offices: 1945 West Parnell Road, Jackson, Ml 49201 *.1517) 788-0550 April 1, 1985
- Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING DECAY HEAT REMOVAL CAPABILITY (MULTIPLANT ACTION NUMBER B-57)
NRC letter dated June 26, 1984 requested a response to the enclosed request for.additional information regarding decay heat removal within 45 days of receipt of the letter.
Consumers Power Company letter dated August 10, 1984 informed the NRC that upon review of June 26, 1984 request for additional information, we had concluded that some changes to the Palisades Plant Technical Specifications (TS) may be warranted and that a complete response would be submitted by the end of December, 1984.
Consumers Power Company letter dated December 20, 1984 notified the NRC of an additional delay in respon,ding to the June 26, 1984 NRC letter, and committed to submit a response, including any proposed TS change requests, by the end of March, 1985.
Responses to the NRC request are provided in Attachment 1 to this letter. is a table which compares pertinent Palisades Plant TS with*the appropriate Standard Technical Specifications (STS) for Combustion Engineering Plants for Hot Standby, Hot Shutdown, and Cold Shutdown conditions.
Consumers Power Company has concluded that the Palisades Plant TS would be improved by adding a surveillance requirement to verify that at least one shutdown cooling.
pump and one shutdown heat exchanger is in operation during refueling operations.
A proposed TS change request to include this surveillance requirement in the Palisades Plant TS will be submitted by the end of April, 1985.
Brian D Johnson Staff Licensing Engineer
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8504040209 850401
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PDR ADOCK 05000255 l 1
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CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades
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Attachment OC0385-0 l,63A-NL04
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I
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)'ffi0385-0163C-NL04 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING DECAY HEAT REMOVAL CAPABILITY April 1, 1985 6 pages
1 ATTACHMENT 1 NRC Request #1 For startup and power operation (Modes 1 & 2) the Standard Technical Specifications (STS) require both RC loops and both RC pumps in each loop to be operating.
The Palisades Plant Technical Specifications (TS) have a similar requirement.
The STS also require verification of RC pump and RC loop operation on a 12-hour basis, and with less than the above required RC pumps in operation the plant should be in hot standby mode within one hour.
The intent of the STS requirement is to assure the RC pumps and other supporting equipment are monitored to detect degrading performance.
Palisades TS do not have the surveillance requirement and permit 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> operation to restore the inoperable pumps(s) before the reactor is to be in the hot standby mode.
The technical justification for Palisades not meeting the STS requirement is not clear to the staff.
Provide justification to demonstrate why the surveillance requirement is not necessary or propose modifications to your TS consistent with the STS.
Also justify permitting 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of operation, rather than one hour permitted in the STS, before the reactor is to be in the hot standby mode, or propose suitable modifications to your TS.
CPC Response In the power operation mode, Palisades Plant TS Table 4.1.1 require that the reactor coolant flow channel of the Reactor Protective System (RPS) be checked every twelve hours by comparison of the four separate total flow indications.
By requiring this surveillance the Palisades Plant TS meet the intent of the suggested surveillance requirements of STS for this mode of operation.
Other alarms monitor reactor coolant pump (RCP) parameters to detect degraded RCP performance.
In addition, RCP parameters are checked every eight hours by operators and recorded on logs.
These log readings are taken as part of the surveillance program.
In discussing the operating time allowed with less than four pumps in operation, it should be noted that Palisades was originally designed to operate continuously with less than four reactor coolant pumps in operation, if necessary.
The presence of the RPS low flow trip provides assurance that, should a reactor coolant pump trip with the plant at power, the reactor will also trip, thus putting the plant in hot shutdown within one hour.
In addition, Table 2.3.1 in the Palisades Plant TS limits the reactor power level for less than four pump operation. The intent of STS is to assure adequate coolant flow through the core.
The Palisades Plant RPS assures that, should there not be enough coolant flow the reactor would trip, thus meeting the shutdown time requirement of the STS.
The Palisades Plant can operate with less than four reactor coolant pumps only under special circumstances, and with specific operator action.
As is stated in Table 2.3.1 of the Palisades Plant TS, operation with two or three pumps is permitted to provide a limited time for repair/pump restart, to provide for an orderly shutdown or to provide for the conduct of reactor internals noise monitoring test measurements.
NU0385-0163C-NL04
2 Consumers Power Company concludes that this is a reasonable exception to the requirement to be in hot standby within one hour.
Therefore, no change to the Palisades Plant TS is necessary.
NRC Request 112 For hot standby operation, the STS require that two reactor coolant loops shall be operable, including the SG and at least one associated RC pump in each loop, and that at least one of the RC loops is operating.
If these conditions are not met and corrective actions cannot restore both loops to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, the reactor is to be in 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 />.
Boron dilution operations are to be stopped if an RC loop is not operating.
The STS also require verification 'that at least one RC pump is operable once per seven days and at least one RC loop is in operation at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
The Palisades TS require both steam generators to be operable during this mode of operation.
When RCS boron concentration is being diluted, the TS require that at least one RC pump be operating, otherwise there is no requirement on the TC pump operability.
The TS also do not have any surveillance requirements or action items comparable to the STS items for this mode of operation.
It is not clear how Palisades TS requirements would satisfy the intent of the STS limiting condition for hot standby.
Provide discussions of how the existing TS meet the intent of the STS for a redundant means of decay heat removal and how the existing TS meet the intent of the STS's surveillance requirements and action items for hot standby mode.
Alternately, propose new technical specifications to meet the intent of the STS.
CPC Response Regarding the Palisades Plant TS limiting condition for operation, the Palisades Plant TS require that both steam generators be capable of performing their heat transfer function whenever the average temperature of the primary co.olant is above 325°F.
This is another way of stating that there are two ways of cooling the reactor.
According to the Palisades Plant Final Safety Analysis Report (FSAR), the reactor coolant pumps are not necessary to take the plant to hot shutdown and maintaining hot shutdown.
This is because natural circulation is a safe and effective method for decay heat removal wit~out operable or operating RCPs.
For the above reasons Consumers Power Company concluded that the Palisades Plant TS meet the intent of STS in that both require redundant means of decay heat removal.*
Even though no action statements are listed in the section of the TS that discusses the operability of the steam generators, Section 3.0 of the TS has general action statements that would apply to the steam generator limiting condition of operation.
This general action statement requires the plant to be in hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> upon the loss of a steam generator.- This is consistent with the STS requirement of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Therefore, no change to TS is warranted.
NU0385-0163C-NL04
In regards to the surveillance requirements in the STS, Table 4.1.1 of the Palisades Plant TS require that the steam generator level be checked every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by comparison of the four level indications per generator.
This same table also requires the steam generator pressure be checked every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by comparison of the four pressure indications.
Since this surveillance is equivalent to that of the STS, the Palisades Plant TS meet the intent of STS.
3 As was stated earlier, the RCPs are not necessary to maintain the plant in hot shutdown.
Since there are no limiting conditions for operation on the RCP in the TS, no RCP surveillance requirements should be included in TS.
Operating RCP do have alarms to detect degraded RCP performance and RCP parameters are checked every eight hours by operators as part of their routine log readings.
In addition, controls are in place to keep the operations personnel aware of the status of pump breaker alignments.
Lack of power to the buses.that supply the RCPs would be detected by undervoltage relays and alarmed.
NRC Request #3 The STS for the hot shutdown mode require at least two loops that are capable of removing decay heat to be operable.
Either two reactor coolant loops (including the associated steam generators) and at least one associated RC pump per loop or the two RHR loops or one loop of each type must be operable.
The STS also require one of the above loops to be operating.
If these conditions are not met and immediate corrective actions cannot restore the required loops to operable status, the reactor is to be in the cold shutdown mode within 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />.
Boron dilution operations are to be stopped if an RC loop is not operating.
In addition, the STS require that the RC pump's operability be verified once per seven days, and at least one coolant loop shall be verified to be operating once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
For the cold shutdoWn mode, the STS require that two RHR loops be operable and at least one loop to be operating. Otherwise, immediate action must be taken to restore the required loops to operable status as soon as possible.
The STS also require that boron dilution operations be suspended if no RHR loop is operating, and that RHR loop operation should be verified once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
The Palisades TS only require both steam generators to be operable in mode 4; no coolant loops are required to be operating.
For both modes, the TS also require that at least one RC pump or one shutdown cooling pump be operating but only when the RCS boron concentration is being changed.
The RHR heat exchangers are not required to be operable when using a shutdown cooling pump.
The TS also do not contain any surveillance requirements meeting the intent of the STS limiting condition.
Provide a discussion or justification of how the existing TS meet the STS intent for a redundant means of decay heat removal for both modes 4 and 5.
Also discuss how the existing TS meet the intent of the STS surveillance requirement for both modes.
Otherwise, propose new technical specifications to meet the intent of the STS.
CPC Response In the hot shutdown mode, the Palisades Plant TS require two steam generators to be capable of performing their heat transfer function.
This assures the NU0385-0163C-NL04
4 redundant core cooling capability.that is the intent of STS.
In addition, at least one RCP or one shutdown cooling pump shall be in operation whenever a change is being made in the boron concentration of the primary coolant.
Since the Palisades Plant TS in essence require two coolant loops to be operable in the hot shutdown mode and during a change in boron concentration, either a RCP or a shutdown cooling pump is required to be operating.
Accordingly, the intent of the STS is met.
As stated earlier, the RCPs are not necessary to maintain the plant in hot shutdown; therefore, no requirements on their operability are included in TS.
With less than two steam generators operable, the Palisades Plant would be required to be in cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> according to Section 3.0 of the Palisades Plant TS.
This is similar to STS.
Therefore, no change to the Palisades Plant TS is warranted.
In the cold shutdown mode, the Palisades Plant TS require one primary coolant pump or one shutdown cooling pump to be in operation whenever a change is being made in the boron concentration of the primary coolant.
Therefore, with no coolant loop in operation, all operations involving a reduction in boron concentration would be suspended.
With no coolant loop in operation, the STS require all operations involving a reduction in boron concentration be suspended.
The end result of both the Palisades Plant TS and the STS is the same.
Therefore, no change to the Palisades Plant TS is necessary since the Palisades Plant TS meet the intent of STS.
Regarding the suggested surveillance requirement that one coolant loop be verified to be in operation and circulating reactor coolant at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the Palisades Plant TS require either a reactor coolant pump or shutdown cooling pump be in operation when changing the boron concentration of the reactor coolant system.
Changing of the boron concentration of the Palisades Plant primary coolant is accomplished in batches and the duration of this operation lasts less than the surveillance interval of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Since' either the shutdown cooling or primary coolant pumps are required to be checked to be in operation prior to a batch being run, a 12-hour surveillance is not necessary.
Again, no change to Palisades Plant TS is needed.
Regarding the redundancy of the Palisades Plant shutdown cooling capacity, there are backup actions that can be taken to make shutdown cooling more reliable.
One action is to line up a high pressure safety injection pump to provide shutdown cooling flow in the event of failure of both low pressure safety injection pumps.
Also, when the reactor cavity is full, the spent fuel cooling system can be used to backup shutdown cooling.
NRC Request #4 For refueling operation (mode 6), the STS require that at least one RHR loop be operating.
If the water level above the top of the reactor vessel flange is more than 23 ft., the STS require that one RHR loop be operable and in operation. If the RHR loop cannot be made operable, the STS require that all refueling operations be suspended, all boron dilution operations are prohibited, and containment penetrations providing direct access to the environment must be isolated within four hours.
Also, at least on shutdown coolant loop shall be verified to be in operation once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
NU0385-0163C-NL04
5 If the water level above the top of the reactor vessel flange is less that 23 ft., the $TS require that two RHR loops be operable, with one in operation.
With less than required shutdown cooling loops operable, the STS require the operator to immediately initiate a corrective action to return the required loops to operable status.
The Palisades TS require at least one shutdown coolant loop to be in operation for refueling mode.
There are no verification requirements on the operating shutdown cooiing loop, or the operable status of both shutdown cooling loops.
The TS also do not specify water level above the top of the reactor vessel flange and the appropriate equipment and actions required.
Provide justification or alternative means to assure that the STS intent for a redundant means of decay heat removal can be met.
Also provide a discussion why the action items surveillance requirements and the specific water level above the top of the reactor vessel flange and the appropriate equipment and actions required by STS are not necessary.
Alternately propose new technical specifications meeting the STS requirements.
CPC Response In the refueling mode, the Palisades Plant TS section 3.8.1.f requir~s at least one shutdown cooling pump and heat exchanger be in operation.
If the above condition is not met all refueling operations shall cease and work shall be initiated to satisfy the required condition and no operations that could change the core reactivity shall be made.
Also, the Palisades Plant TS require containment integrity be established whenever the plant is above cold shutdown.
This means that with no shutdown cooling loop in operation, containment integrity must be established prior to the primary coolant reaching 210°F.
Consumers Power Company prefers to base the establishment of containment integrity on primary coolant temperature rather than on a fixed time period of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, since the time it takes for the primary coolant to heat up can vary due to many factors, such as the amount of time the plant has been shut down.
For the above reasons Consumers Power Company concludes that the Palisades Plant TS meet the intent of the STS.
The Palisades Plant TS do not require the same level of surveillance as the STS in the refueling mode.
A change to the TS in this area would, be beneficial.
Therefore, a change to the TS will be proposed td require a surveillance to be performed to verify at least one shutdown cooling pump and one heat exchanger be in operation at least every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during refueling operations.
In regards to the reactor cavity water level, Consumers Power Company has concluded that changing the Palisades Plant TS to meet the STS would serve no purpose.
The STS require one loop to be in operation for all water levels and two loops to be operable with the water level below 23 feet.
The Palisades Plant TS are more restrictive in that, regardless of water level above the reactor vessel flange, with the loss of both shutdown cooling loops the required action is to suspend all operations involving an increase in reactor decay heat load or a reduction in boron concentration of the reactor coolant system.
Therefore, the same result is accomplished by the Palisades Plant TS and the STS.
Accordingly, no change to the TS is warranted.
NU0385-0163C-NL04
Other periodic checks are performed at the Palisades Plant to help ensure a safe-refueling operation.
Water temperatures are recorded hourly to ensure that the water temperature does not get too high.
Levels in the spent fuel pool and reactor cavity are maintained at a safe level; according to the refueling operations procedure, the minimum allowable level is one foot below the skimmers and both the reactor cavity water level and the spent fuel pool low level alarm are checked each shift.
NU0385-0163C-NL04 6
NU0385-0163C-NL04 ATTACHMENT 2 Consumers Power Company Palisades Plant Docket 50-255
SUMMARY
TABLE COMPARING THE SUGGESTED STS REQUIREMENTS TO THE CORRESPONDING PALISADES TS REQUIREMENTS April 1, 1985 9 pages
Description LCO Action Mode Comparison keff Palisades TS
% Power Tave
> 2%
> 525°F 25%
> 300°F POWER AND STARTUP OPERATION CE - STS Both reactor coolant loops and both reactor coolant pumps in each loop shal I be in operation.
With less than the above required reactor coolant pumps in operation be in HOT STANDBY within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
Palisades Four primary coolant pumps shall be in operation when-ever reactor is operated continually above 5% power (Operation with less than 4 pumps is permitted as des-cribed in Table 2.3. 1).
Both steam generators shall be capable of performing their heat transfer function whenever the average tempera-ture of the primary coolant is above 325°F.
With one or more pumps out of service, return the pumps to service (return to four pump operation) or be in hot stand-by (or below) within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Startup (abo0e hot standby) with less than four pumps is not permitted.
Resolution Pal isdes TS meet intent of CE-STS.
No change required.
Table 2.3. 1 *footnote 4 states 110peration with two or three pumps is permitted to provide a I imited time for repair/pump restart,~
to provide for an orderly shutdown o~
to provide for the conduct of reactor internals noise monitoring test measurements. 11 Reactor Protective System Trip Setting Limits are adjusted according to number of pumps in operation.
Palisades TS meet intent of CE-STS.
No change required.
It is a reasonable time constraint to be in at least hot standby within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
CE-STS provides no basis A for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> time constraint.
lllllmlll"
Description Surveillance POWER AND STARTUP OPERATION continued CE -
STS The above required reactor coolant pumps shall be verified to be in operation and circu-lating reactor coolant at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Pali sades Table 4. 1.1, i tern 3 requires comparison of our separate, total reactor coolant flow indications at least once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Table 4. 1. 1, item 6 requires comparison of four steam generator level indications per generator at least once every 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />s~
Table 4.1. 1, i tern 7 requires comparison of four steam generator pressure indica-tions per gen~rator at least once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Resolution Palisades TS meet intent of CE-STS, rio change required.
Description LCO Action CE - STS Two reactor coolant loops shall be operable including the S/G and at least one associated PC pump in each loop.
At least one reactor coolant loop shall be in operation.
With less than the above re-quired reactor coolant loops operable restore the required loops to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in 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 />.
With no reactor coolant loop in operation, suspend all opera-,,
tions involving a reduction in boron concentration of the reactor coolant system and immediately initiate corrective action to return the required loop to operation.
Mode Comparison keff
% Power Tave
/ 525 Pal TS
( 2%
CE -
<-99 FOR HOT STANDBY Palisades Section 3.1.1.d, both steam generators shal 1 be capable of performing their heat transfer fuction whenever the average temperature of the primary coolant is above 325°F.
Section 3.03, when LCO is not met within one hour* initiate action to place unit in hot shutdown.
Be in hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Be in hot shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Section 3. 1. 1 a, at least one primary coolant pump or one shutdown cooling pump shall be in operation whenever a change is being made in the boron concentration of the primary coolant.
0
) 3DO Resolution Palisades can safety shutdown without reactor coolant pumps.
Therefore redundant cooling capabilities is accomplished by having two steam generators operable in this mode.
No change is necessary.
The action statements in Palisades TS meet the intent of STS in this mode.
In this case Palisades allows a shutdown cooling pump to be used in the event a primary coolant pump is not available.
This is acceptable since, as was stated earlier, primary coolant pumps are not necessary because natural circulation could be used.
Description Survei I lance CE - STS At least the above required reactor coolant pumps if not in operation shal I be determined to be operable once per 7 days by verifying correct breaker alignments and indicated power ava i lab i I i ty.
At least one cooling loop shall be verified to be in operation and circulating reactor coolant at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
FOR HOT STANDBY continued Palisades None Table 4.1.1, Item 6 requires comparison of four steam generator level indications per generator at least once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Table 4. 1. 1, i tern 7 requires compa~ison of four steam generator pressure indications per generator at least once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Resolution Reactor coolant pumps are not necessary in this mode, therefore, no surveillance requirements exist for their operability.
Palisades TS meet the intent of STS.
No change required.
Description LCO Action CE - STS At least two loops that are capable of removing decay heat are operable.
Either two reactor coolant loops (in-cluding the steam generator) and at least one pump per loop of the two RHR loops or one of each type must be operable.
At least one of the above loops shall be in operation.
With less than the above required coolant loops operable, immediately initiate corrective actioh to return the required coolant loops to operable status as soon as possible; be in cold shut-down within 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />.
With no coolant loop in opera-tion, suspend al 1 operations involving a reduction in boron concentration of the reactor coolant system.
Mode Comparison keff
% Power Tave P~lisades TS Subcritical 0
/ 525 CE -
(.99 HOT SHUTDOWN Palisades TS Both steam generators shall be 6apable of performing their heat transfer function when-ever the average temperature of the coolant is above 325°F.
Section 3.03.
When one steam generator becomes inoperable, within one hour initiate action to place unit in cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
At least one primary coolant pump or one shutdown cooling pump shall be in operation whenever a change is being made in the boron toncentra-t ion of the primary coolant.
0 3000F?Tave)2000F Resolution In the Palisades hot shutdown mode two steam generators are required to be operable, thus providing the redundant cooling capability which is the intent of STS.
No change is necessary.
The suggested requirement to initiate corrective action to return the equipment to operable status as. soon as possible would do nothing to improve TS since it is so vague.
Pali-sades TS meet the intent of STS.
No change is necessary.
Palisades TS meet the intent of STS. e No change is necessary.
Description Surveillance CE -
STS The required shutdown cooling loop shal 1 be determined operable per Specification 4.os.
The r~quired reactor c6olant pumps, if not in operation, shall be determined to be operable once per 7 days by verifying correct breaker alignment and indicated power availability.
The required steam g~nerator shall be determined operable by verifying the secondary side water level to be at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
At least one coolant loop shall be verified to be in operation and circulating reactor coolant at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />..
HOT SHUTDOWN continued Pa 1 i sades Section 4.6.3.
The shutdown cooling pumps shal 1 be tested at intervals not to exceed three months.
None.
Table 4. 1. 1, i tern 6 requires comparison of four steam generafor level indications per generator at least once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
None.
Resolution Palisades TS meet the intent of STS.
No change is necessary.
This suggested requirement is not necessary since the reactor coolant pumps are not necessary jn this mode.
Palisades TS meet the intent of STS.
No change is necessary.
Palisades TS require either a RC pump or shutdown cooling pump be in opera-tion when changing the boron concen-tration of the reactor coolant system.
The changing of the boron concentration is accomplished in.batches lasting less than the surveillance frequency~
of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Since the pumps are
~
checked to be in operation prior to the batch being runJ a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> surveillance is not necessary.
No TS change is needed.
Description LCO Action Surveillance CE -
- a.
At least two of the coolant loops 1 isted below shall be operable:
- l.
Reactor coolant loop (A) and its associated steam genera-tor and at least one associ-ated reactor coolant pump,
- 2.
Reactor coolant loop (B) and its associated steam genera~
tor and at least one associ-ated reactor coolant pump.
- 3.
Shutdown cooling loop (A)
- 4.
Shutdown cooling loop (B)
- b.
At least one of the above coolant loops shall be in operation.
With no coolant loop in opera-tion suspend all operations including a reduction in boron concentration of the reactor coolant system and immediately initiate corrective action to return the required coolant loop to operation.
See Hot Shutdown Mode Palisades TS STS COLD SHUTDOWN Pa 1 i sades TS None See action statement below.
At least one primary coolant pump or one shutdown cooling pump shall be in operation whenever a change is being made in the boron concentra-tion of the primary coolant, See Hot Shutdown Come_ar i son
% power Tave
\\
ef 9
< 210°F
<. 9 0
~
S
- D
- boron 0
< 200°F r
concentration Resolution Since the action statement for this suggested STS requirement is to put the plant in cold shutdown, no TS change is necessary since in this mode the plant is already in cold shutdown.
~
Palisades TS meet the intent of STS.
No change is necessary.
Palisades TS require operations involving a change in boron con-centration be suspended when no shut-down cooling loops are avai !able.
This is the same result that would be achieved with the suggested require-ment i~ STS.
No change is necessary.
See Hot Shutdown
Description LCD Action 1
I REFUELING OPERATIONS CE - STS At least one shutdown cooling loop shall be in operation.
Two independent shutdown cooling loops shall be operable.during refueling when the water level above the top of the irradiated fuel assemblies seated within the reactor pressure vessel is less than 23 feet.
- a.
With less than one shutdown cooling loop in operation ex-cept as provided in b. below, suspend all operations involv-ing an increase in the reactor decay heat load or a reduction in boron concentration of the reactor coolant system.
Close al 1 containment pene-trations providing direct access from the containment atmosphere to the outside atmosphere within.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
- b.
The shutdown cooling loop may be removed from operation for up to one hour/eight hours during core alterations in the vicinity of the hot legs.
- c.
3.03 are not appJicable.
Palisades TS Resolution Section 3.8. 1.f.
At least one Palisades TS meet the intent of STS.
shutdown cooling pump and heat No change is necessary.
exchanger shall be in operation during any refueling operations.
None Section 3.8.2.
If any of the conditions in 3.8. 1 are not met, all refueling operations shall be initiated to satisfy the required conditions and no operations that may change the reactivity of the tore shall be made.
Section 3.6.1 ~rid definitions:
Containment integrity shall not be violated unless the reactor is in the cold shut-down condition.
(Tave< 21 QOF).
None No change is necessary becau~e the same action is accomplished by Palisades present TS (see Action Statement).
Palisades TS meet the intent of STS.
No change is necessary.
It is better to base the establish-ment of containment integrity on Tave rather than on a fixed time
.A since the heat up time can vary due-~
to factors such as the length of time the reactor has been shut down.
No change is necessary.
Description Act ion Survei 1 lance CE - STS
- a.
With 1 ess than the required shutdown cooling loops operable initiate corrective action to return loops to operable status as soon as possible.
- b.
Specification 3.0.3 are not applicable.
At least one shutdown cooling loop shall be verified to be in operation and circulating reactor coolant at a flow rate of greater than or equal to (3000) gpm at least once per four hours.
/fie
.:f-i-marrequ ired shutdown coo 1 i ng loops shall be determined operable per Specification 4.0.5.
REFUELING OPERATIONS Palisades TS None None Section 4.6.3.
The shutdown cooling pumps shall be tested at intervals not to exceed three months.
Resolution No change to Palisades TS is necessary.
The suggested STS requirement is vague and does nto require any definite action nor any definite time period for returning the equipment to an 9perating status.
,t l
Suggest changing TS to add appropriat~
surveillance requirement.
Palisades TS meet the intent of STS.
No change is necessary.