ML18053A550
| ML18053A550 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/02/1988 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML18053A551 | List: |
| References | |
| GL-83-37, GL-87-09, GL-87-9, TAC-M54555, NUDOCS 8809070320 | |
| Download: ML18053A550 (6) | |
Text
consumers Power POW ERi Nii llllUllliAN'S PIUl&RESS General Offices:
1945 West Parnell Road, Jackson, Ml 49201 * (517) 788-1636 September 2, 1988 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
TECHNICAL SPECIFICATIONS CHANGE REQUEST REVISION -
CORE EXIT THERMOCOUPLES (TAC NO. M54555)
Kenneth W Berri Director Nuclear Licensing Enclosed is a request to change the Palisades Technicai Specifications.
This change request modifies a submittal of November 25, 1987, and is in response to NRC questions.
This replaces the previous submittal in its entirety.
This change request is similar to one proposed and approved as Amendment No.
110 for the Fort Calhoun Station.
Editorial changes have been made to ensure proper action is taken if less than four environmentally qualified core exit thermocouples (CETs) per core quadrant are operable.
As in our November 25, 1987 submittal, we again propose the core exit thermocouple calibration frequency to be each r~fueling outage instead of 18 months as in Standard Technical Specifications (STS) provided in Generic Letter 83-37.
Like the STS, the Fort Calhoun Station Amendment also included an 18 month calibration frequency.
At Palisades the incores are calibrated per Technical Specification 4.18.1.1 on a refueling cycle basis and since the CETs are contained within the same assembly as the incores, the CETs are calibrated at the same time.
If the refueling cycle were to exceed 18 months, as it presently has, an added radiation dose of about 800 millirem would result from performing the calibration separately.
The CETs are not subject to instrument drift since their output is based on a voltage signal generated from two dissimilar metals.
- Instead, their typical failure mode is an open circuit which is easily detectable during the monthly channel check.
The proposed Technical Specifications-Change Request (TSCR) will require that 4 CETs per core quadrant be operable vice the 2 CETs per core quadrant required by the earlier TSCR.
The proposed TSCR will, however, allow continued operation with less than 4 CETs per core quadrant operable if the reason for the inoper-ability is, for example, a failure of the detector instrument loop which can only_be repaired during a shutdown or refueling outage.
If a detector were to fail, the proposed Technical Specification will require that a letter be provided to the NRC within 30 days documenting actions taken, the cause of the loss of the operable CETs and plans for restoring the CETs to operable status.
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Nuclear Regulatory Commission Palisades Plant TSCR Revision - Core Exit Thermocouples September 2, 1988 2
The minimum degree of redundancy has been changed from "l" to "none" in this proposal.
Degree of Redundancy, as defined in Technical Specification Section 1.2, applies to equipment which have an automatic system trip.
This definition does not apply to the CETs and, therefore, the change was made.
The permissible bypass condition has been also changed from our earlier proposals. It had been "Not required in cold or refueling shutdown," and is changed to "Not required below 325°F." Although not as restrictive as pre-viously proposed, it is consistent with the STS in GL 83-37 and the Fort Calhoun Station Technical Specification which have applicability in Modes 1, 2, and 3.
For Modes 1, 2, and 3, T-ave is greater than 300°F which is the plant condition when not on shutdown cooling, and is the basis for 325°F in the present proposal.
Footnote "l" to Table 3.17.4 has been added to ensure that, if a CET is inoperable, startup may be accomplished.
Technical Specification 3.0.4 restricts changing modes when in an Action statement.
Consumers Power Company will be submitting another change request consistent with Generic Letter 87-09 (Sections 3.0. and 4.0 of STS), in the near future.
That change will revise specification 3.0.4 and eliminate the need for footnote (1) as proposed in this TSCR.
Should review of this change follow the changes to Section 3.0 and 4.0 we request footnote (1) to be deleted.
A final revision to the November 25, 1987 TSCR submittal was made to delete the alpha-numerical quadrant locations of the CETs in the specification and instead identify the CETs as the environmentally qualified CETs.
This change is simply to mitigate any future need for a TSCR if the location of one of the environmentally qualified CETs would have to be relocated.
A check for $150.00 accompanied our previous November 21, 1985 submittal for Core Exit Thermocouples.
We request that application fee be applied to this revision.
We request that the amendment become effective upon issuance.
Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, NRC NRC Resident Inspector - Palisades Attachment OC0888-0088-NL04
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 a new item to Table 3.17.4 and add footnotes (1), (m), (n) and
( o) as follows:
Minimum Minimum Permissible Operable Degree of Bypass "No Function Unit-Channels Redundanc:2:
Conditions
( )
Core Exit 4/Core Quad-None Not Required Thermocouples rant (l,m,n,o) below 325°F.
(1)
The provisions of Specification 3.0.4 are not applicable.
(m)
The environmentally qualified core exit thermocouples are used in determining the minimum operable equipment.
(n)
With the number of OPERABLE Core Exit Thermocouples less than four per core quadrant but greater than or equal to two per core quadrant, in lieu of the requirement of 3.17.2, either restore the inoperable channel(s) to OPERABLE status within 7 days if repairs are feasible without shutting down or prepare and submit a Special Report to the Commission within 30 days following the event outlining the action taken, the cause of the inoperability and the plans and schedule for restoring the system to OPERABLE status.
(o)
With the number of OPERABLE Core Exit Thermocouples less than two per core quadrant, in lieu of the requirements of 3.17~2, either restore two core exit thermocouples per core quadrant to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, or be in HOT SHUTDOWN or below within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />."
B.
Add a new item to Table 4.1.3 and add -footnote (6) as follows:
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"No Channel Description 21 Core Exit Thermocouples (6)
Function Frequency a) Check M
b) Calibrate (6)
Surveillance Method a) Comparison of Channels 2
b) Known voltage substituted for thermocouple (6)
Only applicable to the environmentally qualified core exit thermocouples.
These thermocouples will be calibrated on a refueling cycle frequency."
C.
Add new paragraph to 3.17 Basis as shown on page 3-77 of page changes and revise references.
II. Discussion The above proposed Technical Specifications changes result from Generic Letter 82-28 which required licensees to submit their plans for installing instrumentation for the detection of inadequate core cooling.
Palisades has upgraded the range of the subcooling margin monitor, upgraded the qualification and will upgrade the readout capability of sixteen core exit thermocouples, four per core quadrant, and is providing a reactor vessel level monitoring system.
Generic Letter 83-37 provided require-ments for Technical Specifications for NUREG-0737 items, including instrumentation for detection of inadequate core cooling.
These proposed changes to the Technical Specifications incorporate the required changes to the core exit thermocouples portion of core cooling instrumentation.
The proposed operational requirements are similar to those approved in Amendment 110 for the Fort Calhoun Station for Core Exit Thermocouples with the exception that they have been written in a slightly different form and have included a refueling cycle calibration frequency versus 18 months.
The minimum operable channels in Table 3.17.4 of the proposed Palisades Specifications is 4 per quadrant.
The footnote states that if the number of operable CETs is less than four per quadrant, but greater than or equal to two per quadrant, the inoperable channels must be restored to operable status within 7 days of discovery if repairs are feasible without shutting down, or a special report filed with the NRC within 30 days providing the actions taken, the cause of the loss of operable CETs and plans for restoring the CETs to operable status.
These provisions are provided in the event that a CET failure can only be repaired by replacement of the detector which would require a refueling outage to accomplish.
The Fort Calhoun Specification for CETs minimum operable channels has 2 per core quadrant with a footnote like the one for Palisades.
We consider our proposal to lead the reader of the specifications directly to the footnote if a CET is inoperable.
If the number of operable CETs is less than two per quadrant, the inoperable channels(s) must be restored to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or the plant must be in hot shutdown or below within the next 12 OC0888-0088-NL04
hours consistent with Generic Letter 83-37 (STS), for less than minimum channels operable and with the Fort Calhoun Technical Specifications.
3 The proposed calibration frequency of each refueling cycle, versus 18 months as specified in the Standard Technical Specifications, is requested to be consistent with the incore calibration frequency of each refueling cycle provided in Specification 4.18.1.1.
The core exit thermocouples are calibrated when the incore calibration is performed.
If the surveillance frequency is not consistent with the incore calibr-ation frequency, additional calibrations of the *cETs may be required to meet the Technical Specifications.
The resulting added radiation exposure to workers conducting the calibration is estimated to be about 800 millirem.
Since the CETs are not subject to instrument drift, as their output is based on a voltage signal generated from two dissimilar metals, the change of calibration frequency will not affect performance.
The typical failure mode is an open circuit which is easily detectable.
during the monthly checks.
Also, most refueling cycles will not exceed an 18 month interval so the change will typically not involve an actual change in calibration frequency in these cases.
Analysis of No Significant Hazards Consideration Upgrading of the core exit thermocouples was completed during the 1985-86 refueling outage.
Presently, no Technical Specification for the CETs exist.
These proposed changes provide operational requirements consistent with those approved in Amendment 110 for the Fort Calhoun Station while the surveillance frequency has been changed from 18 months to each refueling cycle.
The upgrading of the CETs to provide environmentally qualified thermocouples and increasing the range of the control room temperature indicator will increase the operators ability to monitor core temperatures following an accident.
The addition of these specifi-cations will provide operability and surveillance requirements that do not increase the probability or consequences of an accident previously evaluated in th~ FSAR.
The addition of these specifications also do not create the possibility of a new or different type of accident or malfunction than has been previously evaluated.
The environmentally qualified CETs increased range of temperature indication provide the operator with better monitoring capability.
The Technical Specification requires that a minimum set of equipment be operable and that calibration be performed in cold shutdown.
No new or different type of accident will be created.
Finally, there is no reduction in the margin of safety produced by the incorporation of these environmentally qualified CETs and wider range temperature indication i~to the plant and adoption of these proposed Technical Specifications.
Although the calibration requirements are different than the Standard Technical Specifications, they will normally fall within the same tim~ as a typical refueling cycle which will be about an.18 month period.
Since the failure mode is an open circuit and not instrument drift, the monthly channel check will verify CET oper-ability.
Calibration on a schedule consistent with incore calibration will also result in less radiation exposure if the 18-month surveillance frequency would require more frequent calibration.
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4 III.
Conclusion The Palisades Plant Review Committee has reviewed this Technical Specification Change Request and has determined that this change does not involve an unreviewed safety question and, therefore, involves no significant hazards consideration.
This change has also been reviewed under the cognizance of the Nuclear Safety Board.
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~
David P Hoffman, Nuclear Operations Sworn and subscribed to before me this 2nd day of September, 1988.
Buehrer, Notary Public Jackson County, Michigan My commission expires October 31, 1989 OC0888-0088-NL04