ML18051B488
| ML18051B488 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/30/1985 |
| From: | Vandewalle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML18051B489 | List: |
| References | |
| NUDOCS 8508060155 | |
| Download: ML18051B488 (3) | |
Text
consumers Power
--company- -** ----- -
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General Offices:
1945 West Parnall Road. Jackson, Ml 49201 * (517) 788-1636 July 30, 1985
- Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
TECHNICAL SPECIFICATION CHANGE REQUEST - HPSI FLOW INSTRUMENTS David J VandeWalle Director of
---NuCieai-Licensing --- - -
. Attached are three (3) originals _and thirty-seven (37) conformed copies of a request for change to the Palisades Technical Specifications.
The requested change deletes the operability requirements for the high pressure safety injection (HPSI) flow instruments in Table 3.17.4.
This change was previously requested as part of a change request dated June 25, 1982.
I A check in the amount of $150.00 is enclosed as required by 10CFR170.21.
Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment OC0785-0255C-NL04
CONSUMERS. PdWER.. COMP.ANY Docket 50-255 Request for Change to the Technical Specifications License DPR-20 For the reasons hereinafter set £orth, 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 ~hanged as described in Section I below:
I.
Change Delete item 3 Table 3.17.4, High-Pressure Safety Injection Flow Instruments II. Discussion The above proposed Technical Specifications change is requested because the high-pressure safety injection (HPSI) flow instruments perform no safety function and no cred-it is taken _for these instruments in any accident analysis.
The specification is also overly restrictive as it requires the reactor to be in hot shutdown, per specification 3.17.2, within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> if any instrument is inoperable.
On the other hand, a HPSI pump may be inoperable for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before action to place the reactor in hot shutdown is initiated within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
On July 27, 1985 with one channel inoperable plant production lost 877 MWe, due to action taken to comply with the specification in commencing plant shutdown.
A review of the Standard Technical Specifications (STS) did not identify a similar specification within the STS.
No surveillance specifications
.exist for these HPSI flow instruments within the Palisades Technical Specifications.
For the above reasons Consumers Power Company requests deletion of the specification.
Analysis of No Significant Hazards Consideration Example (vi) in 48FR14870, states, "Although the change either may result in some increase to the probability or consequences.of a previously-analyzed accident or may reduce in some way a safety margin the results of the change are clearly within all acceptable criteria with respect to the system as specified in the Standard Review Plan.
This example is used as.. gui.dance in determining no significant hazards exists for this Technical Specification Change Request.
Although the HPSI flow instruments provide information to the operator that indicates operation of the system (a type D Regulatory Guide 1.97 variable) the instruments do not perform any automatic functions and no credit is taken for them in any accident analysis.
Similar instrumentation (type D) like low pressure safety injection (LPSI) flow indication do not have operability requirements specified within the Technical Specifications.
The STS also do not contain operability of surveillance requirements for these instruments.
Therefore, although the instruments provide operator TSP0785-0255-NL04
information the change is clearly within acceptance criteria within the Standard Review Plan.
III.
Conclusion 2
The Palisades Plant Review Committee and Nuclear Safety Board (formerly Safety and Audit Review Board) have reviewed this Technical Specification Change Request and have determined that this change does not involve an unreviewed safety question and therefore involves no significant hazards consideration.
A copy of this Technical Specification Change Request has been sent to the State of Michigan official designated to receive such Amendments to the Operating License.
CONSUMERS* POWER COMPANY By./f13 [Jd/)_zll R B DeWitt, Vice President Nuclear Operations Sworn and subscribed to before me this 30th day of July 1985.
fey, Notary County, Michiga My commission expires November 5, 1986.
SHERRY l YNN DURFEY Notary Pu~li~, Jackson County,. Mich.
My Comm1ss1on Expires Nov. 5, 1986 TSP0785-0255-NL04