ML18057A410
| ML18057A410 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/21/1990 |
| From: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML18057A409 | List: |
| References | |
| NUDOCS 9008300139 | |
| Download: ML18057A410 (4) | |
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.
Delete section 3.1.le and revise Basis as indicated on page changes.
B.
Change section 3.1.5 Basis as indicated on page changes C.
Delete section 4.4 and associated Basis.
II. Discussion 1
The above proposed Technical Specifications change is requested, to remove requirements that are no longer necessary due to the requirements added, in Amendment 130, to section 4.0:5 of the Technical Specifica-tions, and to remove inappropriate bases statements that pertain to the original steam generators tube plugging criteria.
Section 3.1.le contains the primary and secondary hydrostatic and leak test pressure and temperature requirements.
Section 4.4 also contains leak test requirements in addition to primary coolant system (PCS) post repair weld examination requirements.
The requirements in Sections 3.1.le and 4.4 are also requirements of the ASME Boiler and Pressure Vessel Code Section XI as implemented by Section 4.0.5 of the Technical Specifications. The current code and addenda in use for the present 10-year ISI interval is the 1983 edition and summer 1983 addenda.
Section 3.1.le items 2 through 5 are essentially covered by the system pressure test requirements of section XI of the Code.
The maximum diff~rential pressure of 1380 psi in these sections and the 350 psi differential in section 3.l.le(6) were established in License Amendments No 10 and 20 dated August 30, 1974 and April 26, 1976.
These pressure differential limits were established in accordance with code requirements due to the steam generator tube wastage problems and the establishment of a 64% degradation tube plugging criteria as noted in the current bases statements.
Since the code requirements as implemented by plant procedures will adequately cover these requirements they can be deleted in lieu of section 4.0.5.
Furthermore, the replacement steam generators are without the tube wastage problems.
OC0890-0390-NL02 9008300139 900821-
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PDR ADOCK 05000255 p
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2 Section XI of the Code in Articles IWB-5000 and IWC-5000 establish requirements for system pressure tests including leak tests and hydrostatic tests.
Under these requirements the system test pressures and temperatures will be established in accordance with the system operating conditions, heat-up limitations specified for the system and the plant Technical Specifications.
The specific differential pressure limitations have been specified by the steam generator supplier in accordance with Section III of the Code and will be specified in plant procedures.
These presently established differential pressure limits for the replacement steam generators are 2100 psi, primary to secondary, and 1021 psi, secondary to primary at a minimum temp~rature of 100°F on the secondary side.
The basis to 3.1.5 has been modified to remove the reference to the 64%
criteria and it has been replaced with a paragraph consistent with the basis in the Standard Technical Specifications for the allowable primary to secondary tube leakage limit of 0.3 gpm.
This Palisades Technical Specifications leakage limit is slightly more restrictive than the Standard Technical Specification limit of 500 gallons per day per steam generator (0.347 gpm) and 1 gpm total.
Sub-article IWB-3521 of Section XI establishes the maximum allowable O.D.
indic~tion for cracks, wastage, or intergranular corrosion to not exceed 40% of tube wall thickness.
This criteria will be utilized as the "tube plugging criteria" for the replacement steam generators and will be used in place of the 64% criteria presently established for the original steam generators with the tube wastage.
Section 4.4a requires the primary coolant system leak test to be conducted at not less than a PCS pressure of 2135 psig.
Use of Section XI would require the test to be conducted at not less than the nominal operating pressure which per TS 3.3.lf cannot exceed 2100 psia (2115 psig).
This is considered a negligible difference in the test pressure lower limit and will have no affect on the test results.
Sections 4.4b and c contain specifications for non-destructive examina-tion (NDE). of PCS "strength" welds. NDE requirements are also established by Technical Specification 4.0.5 via Section XI.
Technical Specification 4.0.5 identifies the surveillance requirements for ASME Code Class 1, 2, and 3 components to be conducted in accordance with Section XI of the ASME Boiler and Pressure Vessel Code as required by 10 CFR 50.55 a.
The.code specifies the appropriate NDE requirements.
The code edition utilized at Palisades has been approved by the NRC.
Therefore, although removal of sections 4.4b and 4.4c would delete specific NDE requirements from the Technical Specifications appropriate NRC approved NDE requirements are specified in Section XI.
Our review also indicates this change is consistent with the Standard Technical Specifications an~ the Technical Specifications Improvement Project efforts to develop restructured Technical Specifications.
OC0890-0390-NL02
3 Analysis of No Significant Hazards Consideration The proposed TS changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
This determination is made because the leak test, hydrostatic test and NDE requirements will be governed by the provisions of Technical Specification 4.0.5 and the applicable edition and addenda of Section XI of the ASME B&PV Code as required by 10CFR 50. 55a.
Furtherm*ore, procedural controls will assure that the code allowable maximum differential pressures are not exceeded for the PCS and secondary systems.
Procedures are also established to assure that the welding of PCS components is within code requirements.
This Technical Specifications change does not involve any change in the probability of PCS component failure.
Further, the change has no effect on engineered safety systems and therefore the consequences of an accident are not changed.
The proposed TS changes do not create the possibility of a new or different kind of accident from any previously evaluated.
Again the ASME code requirements assure that the appropriate test pressures are established and not exceeded.
In add it.ion, there are administrative procedures and programs in place to provide assurance that this change in the Technical Specifications will not result in overpressurization of the PCS or secondary system components or degradation of components.
Therefore no new or different accident from any previously evaluated will be created.
The proposed TS changes do not involve a significant reduction in the margin of safety.
Implementation of the appropriate Code requirements specified in TS 4.0.5 and Section XI of the ASME B&PV Code will assure that maximum allowable pressures are not exceeded and ASME Code NDE requirements are met, therefore, there will be no reduction in the margin of safety with respect to the plant operation.
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 been reviewed by the Nuclear Safety Services Department.
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.
OC0890-0390-NL02
CONSUMERS POWER COMPANY To the best of my knowledge, information and belief, the contents of this Technical Specification Change Request are truthful and complete.
By ~ru.
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D avid P Hoffman, Nuclear Operatio Sworn and subscribed to before me this 21th day of August 1990.
~i~
Elaine E Buehrer, Notary Public Jackson County, Michigan My commission expires October 11, 1993 OC0890-0390-NL02 4