ML18057A427

Application for Amend to License DPR-20,revising Tech Spec 4.5.1 Re Statement on Integrated Leak Rate Test

ML18057A427
Person / Time
Site:	Palisades
Issue date:	08/21/1990
From:	Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML18057A425	List: ML18057A424 ML18057A427 ML18057A428
References
NUDOCS 9008310197
Download: ML18057A427 (4)

Text

• 1 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. Change section 4.5.1 to read:

"4.5.1 Integrated Leakage Rate Tests A surveillance test program for the containment overall integrated leakage rate shall meet the 10 CFR 50, Appendix J, Type A test requirements or approved exemptions."

B. Change section 4.5 Basis by deleting the first two paragraphs on pg 4-34 and replacing them with the following:

"The Type A test requirements including pretest, test methods, test pressure, acceptance criteria and reporting requirements or approved exemptions."

C. Correct paragraph 5 of section 4.5 Basis to indicate that the component cooling lines containment isolation valves are closed by a containment high pressure (CHP) signal not a safety injection signal (SIS). Revise the sentence as follows:

" ... except the component cooling lines valves which are closed by CHP only.

II. Discussion The above proposed Technical Specifications change is requested to allow a containment integrated leakage rate test (ILRT) during the upcoming refueling outage to .be conducted, at our option, at a peak pressure test in accordance with the 10 CFR 50, Appendix J. The present specification, 4.5.1 a (2) states that the ILRT will be conducted at the test pressure of about 28 psig, which is equivalent to a reduced pressure test defined in Appendix J.

Specific test requirements have been removed from the Technical Specifications section 4.5.1 as they are appropriately covered in the 10 CFR SO Appendix J requirements. The appendix J requirements are, of course, imposed as a condition of the Palisades license by 10 CFR 50.54 (o).

OC0890-0063-NL04 900831o197 900021 1/{ 1'

~DR c ADOCK 050~~05~\~"

• 2 A statement requiring the surveillance program to be in accordance with the Appendix J requirements provides appropriate control measures, testing requirements, and acceptance criteria for the Type A test. The change to this general format follows the guidance being promulgated in the Technical Specifications Improvement Project. With this change any incorporated and not require a subsequent Technical Specifications change to resolve differences in the Technical Specification and Appendix J, Type A, testing requirements.

In removing the existing ILRT requirements and replacing them with a specification to conduct the surveillance in accordance with Appendix J requirements, deletion of subsection 4.5.le has also removed a condition to include a summary of the leak test of the recirculation heat removal systems. This reporting condition which pertains to the surveillance in section 4.5.3 has existed since the issuance of the initial Palisades Technical Specification and is not a requirement of 10 CFR 50 Appendix J (ILRT and ILRT results are subject to reporting requirements in Appendix J). However, the leak test requirement will remain in section 4.5.3 and therefore the results of the test will be a plant record and retained in accordance with Technical Specification 6.10; therefore, removal of the reporting requirement does not remove the test requirement and the records will remain available for inspection and audit. Furthermore, failure to meet the acceptance criteria is 4.5.3 will result in a licensee event report per 10 CFR 50.73 as a condition prohibited by the plant's Technical Specifications.

If at a later date, during the Technical Specifications Improvement Project, the surveillance test of section 4.5.3 for the recirculation heat removal systems is removed for the Technical Specifications, and appropriate plant surveillance procedure will be required to assure the test is performed and results recorded. The future condition of the Technical Specifications due to the improvement project will then not affect the conduct of the test unless specifically approved by the NRC.

With the exception of the reporting requirement for the recirculation heat removal system test, the changes to the Technical Specification being requested do not reduce the scope of the testing requirements.

The basis for section 4.5 of the Technical Specifications has been modified to reference the Appendix J requirements rather than discuss the test pressure and duration. These specifics are unnecessary in the basis and are replaced with a general reference to Appendix J.

A correction in the 4.5 basis has also been made changing SIS to CHP for the closure signal for the component cooling water isolation valve signal, as described in FSAR Section 9.3.2.3.

OC0890-0063-NL04

• 3 Analysis of No Significant Hazards Consideration (1) Does this Technical Specifications Change involve a significant increase in the probability or consequences of an accident previously evaluated?

No. This change to the Technical Specification will not affect the probability or consequences of an accident previously evaluated. The Technical Specifications change does not affect the integrated leak rate testing program except to allow the option for the test to be conducted at calculated peak containment pressure instead of requiring a reduced pressure test at about 28 psig. The surveillance test will still meet 10 CFR 50, Appendix J requirements. Removal of the requirement to report results of the leak test of the recirculation heat removal (RHR) systems, and the changes to the Basis Statements also have no affect on probability or consequences of an accident.

(2) Does this Technical Specifications Change create the possibility of a new or different kind of accident from any accident previously evaluated?

As above, the change to the Technical Specifications will allow the option for the ILRT to be conducted at peak containment pressure in accordance with 10 CFR 50, Appendix J requirements. The ILRT will be conducted in accordance with appropriate test procedures. Therefore, the change will not create a new or different type of accident.

Furthermore, the change to the RHR systems leak test reporting requirement and the changes to the Basis do not create a new or different type of accident.

(3) Does this Technical Specifications Change Involve a significant reduction in a margin of safety?

The change to the ILRT surveillance test requirements by allowing the option for a test at peak containment pressure in accordance with 10 CFR 50, Appendix J requirements, the minor Basis changes and the deletion of the RHR systems leak test reporting requirement do not affect the margin of safety. The ILRT results provide the assurance that the containment is meeting its design leakage rate requirement thus assuring that the margin of safety has not been reduced.

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.

OC0890-0063-NL04

),

• 4 CONSUMERS POWER COMPANY To the best of my knowledge, informat.fon and belief, the contents of this Technical Specification Change Request are truthful and complete.

David P Hoffman, Nuclear Operations Sworn and subscribed to before me this 21st day of August 1990.

~/~£~

Elaine E Buehrer, Notary Publi~

Jackson County, Michigan My commission expires October 11, 1993 OC0890-0063-NL04