ML18057B379
| ML18057B379 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/15/1991 |
| From: | CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML18057B378 | List: |
| References | |
| NUDOCS 9111200248 | |
| Download: ML18057B379 (24) | |
Text
CONSUMERS POWER COMPANY Docket 50..!255 Request for Change to the Technical Specifications License DPR-20 It is requested that the Technical Specifications contained in Facility Operating License DPR-20, Docket 50-255, issued to Consumers Power Company on February 21, 1991, for the Palisades Plant be changed as described below.
I.
Changes:
The following changes are proposed for the Technical Specifications:
A.
B.
- c.
Renumbering pages to eliminate unused pages.
Clarifying and reordering the definitions.
Moving a non-instrumentation requirement from Table 3.17.4 to Specification 3.11.2, Power Distribution Instrumentation.
1 D.
Rewriting the Engineered Safety Features Instrumentation Settings LCO, Specification 3.16, into the from LCO - Applicability - Action, and adding an Auxiliary Feedwater Actuation setpoint requirement.
E.
F.
G.
H.
I.
J.
K.
Rewriting the Instrumentation Systems LCO, Specification 3.17, in the form LCO - Applicability - Action; moving items between LCO sections to group all instrumentation operability requirements together; locating non-instrumentation requirements with the associated system LCO; and limiting the time an instrument channel may be bypassed.
Moving a non-instrumentation requirement from Table 3.17.4 to Specification 3.21, Heavy Loads.
Changing the Overpressure Protection System Tests, Specification 4.1, and the Safety Injection and Containment Spray System Tests, Specification 4.6, locating all Overpressure Protection surveillance requirements together.
Moving non-instrumentation requirements from Specification 4.1 to Specification 4.6, Safety Injection and Containment Spray System Tests.
Moving a non-instrumentation requirement from Table 4.1.3 to Specification 4.9, Auxiliary Feedwater System Tests.
Moving Instrumentation Systems Tests from Specification 4.1 to a newly written Specification 4.17, locating all instrumentation surveillance requirements together~
Deleting 4 surveillance items formerly in Specification 4.1.
In addition completely rewritten Basis sections have been supplied for the proposed instrumentation specifications, 3.16, 3.17, and 4.17.
2 II. Discussion of Proposed Changes:
A.
Renumbering pages to eliminate unused pages.
- 1.
Section I; Section 3, from page 3-49 on; and Section 4, pages I through I5d and from page 4-75 on, have been renumbered to accommodate the new material and to eliminate the unused page numbers.
The amendment numbers have been moved with the associated text.
- 2.
The Basis sections for the rewritten specifications, 3.I6, 3.I7, and 4.I7, have been page numbered separately from the Technical Specifications themselves.
B.
Clarifying and reordering the definitions:
I.
The headings, I.2, I.3, and I.4 were eliminated as unnecessary.
All retained definitions, except those on existing page I-6, were reworded as full sentences with consistent structure and were listed alphabetically under the headin9 "I.O DEFINITIONS".
The single reference to "Specification I.4 in item 3.6.Ia was changed to "Specification I.O".
- 2.
Those definitions listed on existing pa9e I-6 were kept in a separate section, "I.I MISCELLANEOUS DEFINITIONS, since they all relate to Radiological Effluent Technical Specifications (RETS). Two of these definitions, Gaseous Radwaste Treatment System and Ventilation Exhaust treatment System, should be deleted when RETS are removed by a separate Technical Specifications change request.
- 3.
The word "Condition" was deleted from the definitions below because the defined terms, as used in the Technical Specifications, did not normally include this word.
Power Operation Condition Hot Standby Condition Hot Shutdown Condition Refueling Shutdown Condition Cold Shutdown Condition
- 4.
The "Operating" and "Safety" definitions were deleted; they were not used as defined terms within the Technical Specifications or bases.
- 5.
Section I.2, Protective System definitions; These definitions were deleted. Only "Degree of Redundancy" was utilized as a defined term in the Technical Specifications. The only use of "Degree of Redundancy", in Specification 3.I7, has been removed by this change.
3 B.
Clarifying and reordering the definitions (continued):
- 6.
The "Channel Calibration" definition was rewritten to more closely match that of STS.
An exception phrase was added, to clarify the acceptability of excluding the detector from calibrations of nuclear instrument channels. This exception is provided in the individual LCOs of CE STS.
Channel Calibration (Existing)
Adjustment of channel output such that it responds with acceptable range and accuracy, to known values of the parameter which the channel measures. Calibration shall encompass the entire channel, including equipment action, alarm, interlocks or trip and shall be deemed to include the channel functional test.
CHANNEL CALIBRATION (Proposed)
A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds with the necessary range and accuracy to known values of the parameter which the channel monitors.
The CHANNEL CALIBRATION shall encompass the entire channel including the sensor, alarm, and trip functions, and shall include the CHANNEL FUNCTIONAL TEST.
The CHANNEL CALIBRATION may be performed by any series of sequential, overlapping, or total channel steps such that the entire channel is calibrated. Neutron detectors may be excluded from CHANNEL CALIBRATIONS.
- 7.
The "Channel Check" definition was rewritten to more closely match that from Standard Technical Specifications. A requirement to verify that the measured parameter is within limits was added to CHANNEL CHECK.
Palisades Technical Specifications do not generally have explicit Surveillance Requirements which require such verifications and operating practice has been to make such verifications during each channel check.
- 8.
Channel Check (Existing)
A qualitative determination of acceptable operability by observation of channel behavior during normal plant operation.
This determination shall, where feasible, include comparison of the channel with other independent channels measuring the same variable.
CHANNEL CHECK (Proposed)
A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation. This determination shall include, where possible, comparison of the channel indication and status with other indications and status derived from independent instrument channels measuring the same parameter. A CHANNEL CHECK shall include verification that the monitored parameter is within limits imposed by the Technical Specifications.
The "Low Power Physics Testing" definition minimum temperature specified was changed from 260°F to 371°F to agree with limit in Specification 3.l.3b. This change was submitted on March 5, 1988 and among those withdrawn on January 24, 1989.
B.
Clarifying and reordering the definitions (continued):
- 9.
The "Operability" definition was rewritten to be like that in STS.
A revised definition had been submitted on August 21, 1980 withdrawn on January 24, 1989. The proposed definition is the definition currently used under administrative control and is that used in the latest revisions of the CE STS.
Operable (Existing)
A system or component is operable if it is capable of fulfilling its design functions.
OPERABLE - OPERABILITY (Proposed) 4 A system, subsystem, train, component, or device shall be OPERABLE, or have OPERABILITY, when it is capable of performing its specified functions, and when all necessary attendant instrumentation, controls, electrical power sources, cooling or seal water, lubrication, or other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified functions are also capable of performing their related support functions.
- 10.
The "Refueling Boron Concentration" definition was rewritten to assure that both ~5% shutdown margin and ~1720 ppm are required.
Refueling Boron Concentration (Existing)
Boron concentration of coolant at least 1720 ppm (corresponding to a shutdown margin of at least 5% Ap with all control rods withdrawn).
REFUELING BORON CONCENTRATION (Proposed)
REFUELING BORON CONCENTRATION shall be a Primary Coolant System boron concentration of at least 1720 ppm AND sufficient to assure the reactor is subcritical by ~ 5% Ap with all CONTROL RODS withdrawn.
- 11.
The "Total Interior Rod Radial Peaking Factor" definition was rewritten to delete reference to "interior" rods. This change was intended to be included in the Cycle 9 changes, but was only partially implemented in the change request.
Total Interior Rod Radial Peaking Factor - F; (Existing)
The maximum product of the ratio of individual assembly power to core average assembly power, times the highest interior local peaking factor integrated over the total core height including tilt. Local peaking is defined as the maximum ratio of the power in an individual fuel rod to assembly average rod power.
TOTAL RADIAL PEAKING FACTOR
- Frr (Proposed)
The TOTAL RADIAL PEAKING FACTOR shall be the maximum product of the ratio of individual assembly power to core average assembly power, times the hi~hest local peaking factor integrated over the total core height, including tilt. Local Peaking is defined as the maximum ratio of an individual fuel rod power to the assembly average rod power.
5 C.
Moving a non-instrumentation requirement from Table 3.17.4 to Specification 3.11.2, Power Distribution Instrumentation.
- 1.
- 2.
3.11.2a was clarified by addition of the words "of power operation" in the second line. This change is intended to make 3.11.2a agree more closely with the associated surveillance, SR 4.18.2.1.
Action 3 was reworded to agree, in structure, with the proposed Action 4 [see below].
The final sentence, which simply gave the location of the operability requirements for TM/LP and ASI circuits, was deleted; it is not normal practice to put cross references into Action statements.
3.11.2 ACTION 3: (Existing)
When the measured AO uncertainty is greater than specified in Specification 4.18.2, the TM/LP trip function and the ASI alarm setpoints shall be conservatively adjusted within twelve (12) hours or that channel shall be declared inoperable.
The operability requirements for TM/LP and ASI are given in Table 3.17.1 and 3.17.4, respectively.
3.11.2 ACTION 3: (Proposed)
When the difference between the excore and the incore measured AXIAL OFFSET exceeds 0.02, the TM/LP trip function and the ASI alarm setpoints shall be conservatively adjusted within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or that channel shall be declared inoperable.
- 3.
Action 4 was added to Specification 3.11.2. It was formerly the second half of footnote (g) from Table 3.17.4. The footnote contained two unrelated, dissimilar actions.
The frequency of the specified action was changed from "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />" to "once each 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />" to meet the original intent. Specifying once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> results in the check being required earlier and earlier each shift, to avoid exceeding 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, until one shift has to do it twice; 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is the interval used in STS and existing Palisades Technical Specifications to describe actions required each shift.
Table 3.17.4 entry (Existing, with subject parts underlined)
(g) Calculate the Quadrant Power Tilt using the excore readings at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> when the excore detectors deviation alarms are inoperable, or at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> using symmetric incore detectors when the difference between the excore and the incore measured Quadrant Power Tilt exceeds 2%.
3.11.2 ACTION 4 (Proposed)
When the difference between the excore and the incore measured Quadrant Power Tilt exceeds 2%, calculate the Quadrant Power Tilt at least once each 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> using symmetric incore detectors.
D.
6 Rewriting the Engineered Safety Featurei Instrumentation Settings LCO, Specification 3.16, into the form: LCD/Applicability - Action/Completion Time, and adding an Auxiliary Feedwater Actuation setpoint requirement.
I.
- 2.
Specification 3.16 was rewritten in the form: Specification/
Applicability - Action/Completion Time.
The Table of setpoints has been moved so that it immediately follows the LCO section rather than following the basis.
The "Applicability" statement was rewritten to specify when the specification was applicable, rather than to specify to what it was applicable. This is in keeping with the usage of "applicability" in STS and recently issued Palisades Technical Specifications.
3.16 Applicability: (Existing)
This specification applies to the engineered safety features system initiation instrumentation settings.
3.16 Applicability: (Proposed)
"Specification 3.16 is applicable when associated ESF or Isolation Function instrumentation is required to be OPERABLE by Specification 3.17.2 or 3.17.3."
- 3.
The "Objective" statement was deleted. It serves no purpose and no similar entry appears in STS.
- 4.
- 5.
- 6.
- 7.
- 8.
An "Action" statement was added.
The existing specification provides no corrective action to be completed if the specification is not met.
Plant practice is to declare an instrument inoperable if it is not set in accordance with the specification. This is the proposed Action; it is the Action taken under STS.
Table 3.16 was refo~matted deleting the "Channel" column and the existing footnotes.
The information in the existing column labeled "Channel" has been moved to the basis section for 3.16.
The permissible bypasses have been moved to 3.17.2 or 3.17.3.
A setpoint requirement for Steam Generator Low Level initiation of AFAS was added to Table 3.16. Operability of the instrument and logic channels which provide the AFAS signal is required by existing Specification 3.17, but no setpoint was listed in Table 3.16.
The Pressurizer Low Pressure setpoint for operation at < 1900 psia was deleted; it is no longer needed. This provision was added to the Technical Specifications by Change 4 to Amendment 4, on March 2, 1973, because of concerns about fuel densification and potential fuel rod collapse.
Change 5 to Amendment 4 imposed an 1800 psia upper limit for normal PCS operation pressure in the Interim Technical Specifications. Subsequent improvements in fuel design avoid these potential problems.
The 1800 psi limitation was removed by Amendment 25 on March 11, 1977.
The permissible bypass conditions were moved from Specification 3.16 to the appropriate section of 3.17. Specification 3.16 is limited to the required setpoints, which are not bypassed. Only bistable amplifier and relay contacts are bypassed.
Proposed Specifications 3.17.2 and 3.17.3 provide the permissible bypass information.
- 9.
The Basis section for 3.16 has been rewritten.
The new version addresses set point selection and background on each function.
Additional circuitry and function information is provided in the bases for Specifications 3.17.2 and 3.17.3.
E.
- Rewritin~ the Instrumentation Systems LCO, Specification 3.17, in the form LCO/Appl1cability - Action/Completion Time; moving items between LCO sections to group all instrumentation operability requirements together; locating non-instrumentation requirements with the associated system LCO; and limiting the time an instrument channel may be bypassed.
- 1.
The existing Specification 3.17 was divided into four specifications, each in the form: Specification/Applicability - Action/Completion Time.
Instruments having similar applicabilities and Actions were grouped together. The "Objective" statement was deleted.
It serves no purpose and no similar entry appears in STS.
The Requirements of Tables 3.17.2 and 3.17.3 have been grouped under new headings which more accurately reflect the plant equipment.
Most entries from Table 3.17.4 were moved to proposed Table 3.17.6, "Other Safety Functions". A few were moved to more appropriate LCOs.
7 Existing Specification 3.25, Alternate Shutdown System, was renumbered 3.17.5 to place all instrumentation operability requirements in Specification 3.17.
Two instrument identifiers have been corrected, LI-0102E becomes Ll-01028 to agree with in plant labeling and LT-03328 becomes Ll-03328 since it is the indicator (LI), not the transmitter (LT) which is located at the remote shutdown panel.
The proposed instrumentation LCO sections are:
3.17.1: RPS instrumentation requirements.
3.17.2: ESF instrumentation requirements.
3.17.3: Isolation Function instrumentation requirements.
3.17.4: Accident Monitoring instrumentation requirements.
3.17.5: Alternate Shutdown System requirements.
3.17.6: Other Safety Function instrumentation requirements.
Each Table in Specification 3.17 was rewritten, replacing the "Degree Of Redundancy" column with an "Installed Channels" column.
The degree of redundancy is currently defined in Section 1.2 as "The difference between the number of operable channels and the number of channels which, when tripped, will cause an automatic system trip." Since the tables already contained a "Minimum Operable Channels" column, the Degree of Redundancy column information was redundant and contributed more confusion than usefulness.
The information provided by this column now appears, in a more useful form, in a discussion of each table entry in each associated basis section. The Degree of Redundancy definition has been deleted.
The footnotes of each existin~ table provide a mixture of Action statements, comments, permissible bypass conditions, and general basis information.
In each r.roposed specification, the Action statements have been moved to an 'Action" section which immediately follows the LCO statement.
The remaining items have been placed in the basis, if they were informational, or left as footnotes where appropriate.
Proposed Specification 4.17, Instrumentation Systems Tests, provides 6 tables corresponding to the Specification 3.17 tables, each providing the surveillance requirements for the instrumentation in the 3.17 table.
8 E.
Rewriting the Instrumentation Systems LCO, (continued):
- 2.
Each section of proposed Specification 3.17 has an "Applicability" section written to specify when the specification is applicable, rather than to specify to what it was applicable. This usage of "applicability" is in keeping with the usage of "applicability" in STS and recently issued Palisades Technical Specifications.
3.17 Applicability: (Existing):
Applies to plant instrumentation systems.
3.17 Applicabilities: (Proposed)
Specification 3.17.1 applies when there is fuel in the reactor, more than one control rod is capable of being withdrawn, and the PCS is less than REFUELING BORON CONCENTRATION.
- Specification 3.17.2 applies when the PCS temperature is ~ 300°F.
Specification 3.17.3 applies when the PCS is above COLD SHUTDOWN.
Sp~cification 3.17.4 applies when the PCS temperature is > 300°F.
Specification 3.17.5 applies when the PCS temperature is > 300°F.
According to the Applicable Conditions column of Table 3.17.6.
In existing Specification 3.17, the only "Applicability" information provided is in the "Permissible Bypass Conditions" column and, for Table 3.17.1, footnote (g). The proposed Applicability statements clarify when the subject instrumentation is required to assure that it is operable when needed, and to allow maintenance when it is not.
The applicability for Specification 3.17.1, RPS instrumentation, requires the RPS and associated instrumentation to be operable whenever the RPS could provide its design function of automatic rod insertion (assuming one rod would fail to insert), but allows operating one CROM at a time when the RPS is not operable.
Th~
existing applicability, footnote (g), requires most, but not all, RPS channels to be operable if any CROM is capable of withdrawal.
The existing RPS applicability prevents couplin~ the CRDMs to the control rods after a refueling outage, calibration of rod position indication, measuring rod drop times, and other single rod maintenance and surveillance items from being accomplished while RPS is out of service for maintenance or testing. The proposed allowance for one CROM being capable of withdrawal without a fully operable RPS permits these single rod maintenance activities to be accomplished.
The RPS design, the definition of Shutdown Margin, and the safety analyses all assume one rod will fail to insert on a trip. The design function of the RPS has, therefore, been accomplished any time that all rods but one are fully inserted. With its design function already accomplished, there in no need for an operable RPS.
There is no need for an operable RPS when there is no fuel in the reactor.
The applicabilities for Specification 3.17.2, ESF instrumentation, and Specification 3.17.3, Isolation Instrumentation, require the instrumentation to be operable whenever the supported equipment is required.
Permissible Bypass conditions proposed for Pressurizer Pressure and Steam Generator Low Pressure are unchanged from the existing specifications. The proposed permissible by~ass condition for ESF pump room isolation agrees with the applicabi.ity for the SIS and Containment Spray equipment located in the subject rooms.
9 E.
Rewriting the Instrumentation Systems LCO, (continued):
- 3.
- 4.
5.
The applicability for Specification 3.17.4, Accident Monitoring Instrumentation, was taken from NUREG 0212.
Most of Specification 3.17.4 is comprised of new requirements, the Subcooled Margin Monitor, Wide Range Pressurizer Level, and Reactor Vessel Water Level instruments are required by existing Table 3.17.4. The proposed Applicability for Wide Ran~e Pressurizer Level, >300°F, is less restrictive than the existing requirement, which allows bypassing only in the Cold or Refueling Shutdown condition. This change provides uniformity within the proposed Specification 3.17.4.
The applicability for proposed Specification 3.17.5, Alternate Shutdown System, (>300°F) is unchanged from that proposed by a previously submitted change request for the Alternate Shutdown Specification, 3.25.
The applicability for proposed Specification 3.17.6, Other Safety Functions, is specified separately for each required item using an "Applicable Conditions" column.
The existing Table 3.17.4 lists "Permissible Bypass Conditions" for certain instruments, which provides similar information. This specifying of individual applicabilities is necessary because of the wide variety of safety functions addressed. Table A lists each entry in the proposed Table 3.17.6 with the existing "Permissible Bypass Condition" and the proposed applicability. The justification for each specified applicability is discussed in the basis section~
Completion times were proposed for existing Actions which had none~
The proposed completion time for each inoperable channel is based on its safety function, available redundancy, and availability for repair during power operation. The STS were used for guidance for those channels required by that document.
The proposed Actions for inoperable safety channels limits the time a channel may be bypassed.
Each proposed 3.17 specification has a required Action to be taken if the requirements of the specification and its Action cannot be met.
These Action requirements were copied from the existing Action 3.17.2 which applies to all specified instrumentation. The proposed wording chan~es the requirement from going to Cold Shutdown to gain~ to a condition where the specification does not apply.
The wording was revised to base all completion times on the discovery that the shutdown Action was applicable.
The time requirements are unchanged from existing Specification 3.17.2.
One Permissible Bypass setpoint specification was changed in Table
. 3.17.1 to allow some setting tolerance. The Permissible Bypass Conditions for Hi Startup Rate and Loss of Load trips were formerly specified as > 15% and < 15% rated power, respectively.
The 15% was intended to be a nominal setpoint.
Both bypass switches are provided by the same bistable, and thus these two requirements cannot both be met if 15% is taken as 15 +/- 0%.
The proposed Permissible Bypass Conditions are above 13% for the Hi Startup Rate, and below 17% for the Loss of load. These proposed setpoints permit bistable action to occur at 15 +/- 2%, allowing for hysteresis and avoiding excessive adjustment.
10 E.
Rewriting the Instrumentation Systems LCO, (continued):
- 6.
Different Actions are proposed for inoperable AFAS channels in Specification 3.17.2 than are currently specified in Table 3.17.4 footnote (f).
The Action for a single inoperable channel was changed from requiring a dedicated operator to be in the control room within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, to allowing 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> for repair which is the same Action proposed for other ESF logic channels.
It is proposed that no Action statement is provided for two inoperable AFAS channels thereby requiring a shutdown under Specification 3.0.3.
The existing Action of starting the turbine driven pump accomplishes nothing but additional pump wear since, with the given two inoperable AFAS channels, no automatic signal would be available to open the flow control valves.
- 7.
A new Specification 3.17.4, Accident Monitoring, was added.
The entries in Table 3.17.4 are the Type A and Category 1 entries from Palisades FSAR Appendix 7C.
These include three items formerly in Table 3.17.4.
A note has been included in the proposed Specification 3.17.4 providing an exception to the requirements of Specification 3.0.4.
This exception was provided for two of the three proposed 3.17.4 entries which are current requirements (Wide Range Pressurizer Level, Subcooled Margin Monitor, Reactor Water Level).
The existing specification does not have such an exception for the Subcooled Margin Monitor.
This exception would allow mode changes when a Subcooled Margin Monitor channel was inoperable. Since the Subcooled Margin Monitor provides indication only, it is judged that there is no additional risk incurred by allowing mode changes during the allowed outage time for this equipment.
A 3.0.4 exception is provided in STS.
- 8.
The proposed shutdown Action 3.17.5.3 was changed from the existing 3.25.la to make them similar to other shutdown requirements of the proposed Specification 3.17. The times specified, as explained in the associated basis section, are referenced to the discovery that the Action was applicable, rather than several sequential intervals. The proposed shutdown requirement, which was taken from the RPS instrumentation specification, results in an additional 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowed for reaching Cold Shutdown.
3.25 ACTION:
(Existing - subject portions underlined)
With less than the "Minimum Equipment" in Table 3.25.1 Operable, restore the inoperable equipment to Operable within 7 days, or provide equivalent shutdown capability and restore the inoperable equipment to Operable within 60 days; 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 /> and Cold Shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
3.17.5.2: (Proposed)
If any Action required by 3.17.5.1 is not met AND the associated completion time has expired:
a) b)
The reactor shall be placed in HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and The reactor shall be placed in a condition where the affected equipment is not required, within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
E.
11 Rewriting the Instrumentation Systems LCO, (continued):
- 9.
The "Minimum Operable Channels" column has applied consistently; in existing Table 3.17.4 its has three usage variants:
- a.
Specify a number of channels, below which the plant must be shutdown in accordance with 3.17.2 (most items),
- b.
Specify a number of channels, below which Action stated to be "in lieu of 3.17.2" must be taken (items 8, 15, & 18), and
- c.
Specify a number of channels, below which Action must be taken but only implying "in lieu of 3.17.2" by existence of an Action statement (items 2, 13, & 16).
The Source Ran~e entry formerly required two Operable channels, but allowed operation to continue with only one channel if the wide range channels were providing neutron flux indication. The proposed specification allows continued operation if either the start up or wide range,indication is Operable and on scale. This revised requirement allows operation above the range of the start up channels yet retains the requirement for two Operable channels of neutron flux indication.
The usage of "Minimum Operable Channels" in the proposed Specification 3.17 always requires shutdown when fewer than the specified minimum channels are operable.
The Minimum Operable Channels specified is that number of channels for which continued operation is allowed by the existing specification, with two exceptions (Service Water Break Detector and Subcooled Margin Monitor) which are discussed below. Each table lists the number of installed channels and provides Required Action statements when any installed channels are inoperable.
The Basis document explains this usage.
- 10.
In two instances the proposed number of "Minimum Operable Channels" was reduced from that specified in existing Table 3.17.4.
In each case an Action statement was proposed to stipulate compensatory steps for an inoperable component.
The existing specification only provides a shutdown requirement, which is not always appropriate.
- b.
- b.
The Subcooled Margin Monitor entry formerly specified only one Operable channel and provided no Action other than the 3.17.2 shutdown Action.
The proposed 3.17.4 allows operation to continue for one week with one channel inoperable, and for two days with both channels inoperable, which is the same Action applied to all of the Accident Monitoring Instrumentation. This Action was taken from STS, NUREG 212.
The number of required SWS break detectors was reduced to avoid requiring a shutdown when the SWS break detector is inoperable because the instrument has no safety function.
The function of this instrument is solely diagnostic. It was installed, according to the SWS description (no other documentation could be found), to assist the operator, upon receipt of an alarm, in determining the source of SWS leakage within the containment.
12 E.
Rewriting the Instrumentation Systems LCO, (continued}:
- 11.
- 12.
- 13.
The LCO for PORV Position Indication fn 3.17.6 was changed to allow use of the newly installed stem position indicator as an acceptable means of position detection. Stem position is a more positive means of valve position than tail pipe temperature or acoustic monitoring.
The proposed Specification 3.17.6 contains Operability and applicability requirements for the following instrument channels which currently have only Surveillance Requirements:
- 1.
Second Manual Trip Channel,
- 2.
RPS logic channels,
- 3.
Diesel Generator Load Sequencers,
- 4.
ESF Room Rad Monitors,
- 5.
Rod Position Indication,
- 6.
SIT Level and Pressure,
- 7.
SIRWT Temperature,
- 8.
Main Feedwater Flow,
- 9.
Containment Humidity Detectors,
- 10.
Boric Acid Tank Low Level Alarms,
- 11.
SDC Suction Valve Interlocks,
- 12.
Radiation Monitors.
The proposed Applicability for each channel is bases on its safety function, the applicability of associated safety equipment, and safety analysis assumptions for the channel.
The proposed Action and completion time for each inoperable channel is based on its safety function, available redundancy, and availability for repair during power operation. The STS were used for guidance for those channels required by that document.
A new item of "system logic" was added to Tables 3.17.1, 3.17.2, and 3.17.3. The operability of the logic circuits is clearly required by the Operability definition, but these circuits are not explicitly addressed in section 3 of the existing Technical Specifications.
Logic circuits are addressed in the existing surveillance requirements.
An Action statement (3.17.6.13} was proposed requiring repair of an inoperable Service Water System break detector prior to the next startup. The lack of any explicit Action statement would currently require a shutdown under 3.0.3 if this single, non-safety related instrument should fail. The proposed Action was based on the instrument providing no safety function, and repair of some failures possibly interfering with Service Water System operation.
13 F.
Moving a requirement from Table 3.17.4 to Specification 3.21, Heavy Loads.
- 1.
Specification 3.21 was re-titled from "MOVEMENT OF HEAVY LOADS" to "CRANE OPERATION AND MOVEMENT OF HEAVY LOADS" to accommodate crane limits other than heavy loads.
- 2.
A new item "g.", formerly footnote (a) of Table 3.17.4, was added to 3.21.2. It was relocated to Specification 3.21 in order to put all crane related limitations in the same place.
The paragraphs below show the existing Table 3.17.4 entries and the Proposed item 3.21.2.g.
Table 3.17.4 entrv: (Existing)
(a) Crane shall not be used to move material past the fuel storage pool unless the interlocks are available.
Item 3.21.2g: (Proposed)
- g.
The Fuel Pool Building Crane shall not be used to move material past the fuel storage pool when its interlocks are inoperable.
G.
Changing the Overpressure Protection System Tests, Specification 4.1, and the Safety Injection and Containment Spray System Tests, Specification 4.6, locating all Overpressure Protection surveillance requirements together.
H.
- 1.
The instrumentation surveillance of Specification 4.1.1, items a.I a.2, have been included in the new table 4.17.6.
The balance of existing Specification 4.1.1 has been renumbered as proposed Specification 4.1. These relocations are proposed to locate all instrument surveillance and Low Temperature Over Pressure (LTOP) protection surveillance in the same sections of the Technical Specifications.
- 2.
Items 4.1.1.b and 4.1.1.c were rewritten as proposed items 4.1.b.l, 4.1.b.l.2, and 4.1.b.l.3. The surveillance requirements of these paragraphs were arranged in order of decreasing frequency.
Moving non-instrumentation requirements from Specification 4.1 to Specification 4.6, Safety Injection and Containment Spray System Tests.
and
- 1.
The Applicability and Objective statements of Specification 4.6 were deleted.
The Applicability for surveillance testing is that for the associated equipment as specified in 4.0.1.
The Objective statement serves no function and no similar entry appears in STS.
These changes have been made in each rewritten surveillance section.
- 2.
Existing item 4.6.1.b, which deals with Overpressure protection, was moved to proposed item 4.1.c to locate all Overpressure protection surveillance requirements together.
- 3.
Item 4.6.3.b was reworded to clarify the definition of acceptable performance.
The existing wording specifies "reaching rated shutoff heads at minimum recirculation flow".
The proposed wording requires "reaching rated head on recirculation flow".
The change in wording eliminates concern that the definition limited recirculation flow for testing to that where the pump still maintained shutoff head.
Operating the pumps at such reduced flow is not considered good operating practice.
- 4.
A new section, 4.6.4 Valves, is proposed for the Safety Injection and Containment Spray valve surveillance requirements formerly instrumentation surveillance table 4.1.2, items 8, 19, and 20.
I.
14 Moving a non-instrumentation requirement from Table 4.1.3 to Specification 4.9, Auxiliary Feedwater System Tests.
- 1.
The Applicability and Objective statements were deleted.
The Applicability for surveillance testing is that for the associated equipment as specified in 4.0.1.
- The Objective statement serves no function and no similar entry appears in STS.
These changes have been made in each rewritten surveillance section.
- 2.
References to item 4.3.c, which was previously deleted, were removed from item 4.9.a.l, 4.9.a.2, and from the first Basis paragraph.
- 3.
Item 4.9.a.l and 4.9.a.2 were reworded to include the requirements which were formerly located in Table 4.1.3 item 16a and referenced Table 4.1.3.
J.
Moving Instrumentation Systems Tests from Specification 4.1 to a newly written Specification 4.17, locating all instrumentation surveillance requirements together.
- 1.
Specification 4.17, formerly "Fire Protection (deleted)", was used for instrument requirements to provide numerical correlation between Sections 3 and 4. *
- 2.
The instrumentation surveillance requirements of Specification 4.1, Tables 4.1.1, 4.1.2, and 4.1.3 have been moved to a new Specification 4.17, Tables 4.17.1 through 4.17.6.
Each surveillance requirement is described by use of "Channel Check", "Channel Functional Test", or "Channel Calibration" where possible *
- 3.
The Applicability and Objective statements were deleted. The Applicability for surveillance testing is that for the associated equipment as specified in 4.0.1. The Objective statement serves no function and no similar entry appears in STS.
These changes have been made in each rewritten surveillance section.
- 4.
- 5.
- 6.
Those surveillance re9uirements with a "refueling" interval specified have been changed to' 18 months". This change is proposed to achieve consistency throughout the Technical Specifications and to emulate STS.
The instrumentation surveillance of Specification 4.1.1, items a.I and a.2, have been included in the new table 4.17.6. The balance of existing Specification 4.1.1 has been renumbered as proposed Specification 4.1. These relocations are proposed to locate all Instrumentation surveillance and Overpressure Protection surveillance together.
The Surveillance Requirements for Area Monitors, Table 4.1.3 item 4, have been limited to the Spent Fuel Pool Monitor and the Containment Refueling Monitor.
The existing requirement does not specify to which monitors it applies; there is no corresponding LCD.
The CE STS require operability of and surveillance for those monitors providing automatic actions other than alarm functions.
With the inclusion of operability requirements for the Spent Fuel Pool Monitors and Containment refueling monitors in Table 3.17.6 and of associated surveillance requirements in Table 4.17.6, the Palisades Technical Specifications provide Area Monitor requirements equivalent to those in the CE STS.
15 J.
Moving Instrumentation Systems Tests from 4.1 to 4.17 (continued)
- 7.
- 8.
- 9.
The following Area Monitors are included in this proposal:
Containment Isolation.(Operating), 3.17.3.& 4.17.3; ECCS Pump Room* Isolation, 3.n.3 & 4.H.3, Containment Hi~h Level, 3.17.4 & 4.17.4; SFP Area "Criticality" monitor, 3.17.6 & 4.17.6; Containment Isolation (Refueling) 3.17.6, & 4.17.6, 3.8.1.c)
The interval specified for performance of a Channel Check on the required Pressurizer Level channels, Table 4.1.3 item 7.a, and for the Subcooled Mar~in Monitor, Table 4.1.3 item 18.a, were extended from "Shiftly" to 31 Days" for consistency with other Accident Monitoring (AMI) channel requirements.
The 31 day interval for AMI channels, most of which are added to Technical Specifications by this change request, was copied from STS.
The interval specified for SIRWT temperature and for containment radiation level channel checks was reduced from 31 days and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, respectively, to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for the sake of consistency within the Technical Specifications.
New surveillance requirements have been added to Table 4.2.2, "Minimum Frequencies for Equipment Tests. These surveillance requirements verify closure of the feed water regulating and bypass valves on a Containment High Pressure (CHP) signal, or on a Steam G~nerator Low Pressure (SGLPJ signal each refueling.
The operability requirements for the initiating instrumentation and logic circuits are located in Table 3.17.3:
- 14. Main Feedwater Isolation (Proposed)
- a.
Verify that the Main Feedwater Regulating valve and the associated bypass valve close on an actual or simulated Containment High Pressure (CHP) signal once each 18 months.
- b.
Verify that the Main Feedwater Regulating valve and the associated bypass valve close on an actual or simulated Steam Generator Low Pressure (SGLP) signal once each 18 months.
Main feedwater isolation on Steam Generator Low Pressure (SGLP) was installed in 1981, although there is no requirement for it in Technical Specifications. Main feedwater isolation on Containment High Pressure (CHP) was installed during the Spring 1990 Outage.
At the present time, both the MFW regulating valves (CV-0701, CV-0703) and by-pass valves (CV-0734, CV-0735) close on either CHP or SGLP.
The results of the main steam line break analysis for the new Palisades Steam Generator Project (Enclosure 3) shows that containment design pressure will not be exceeded during a steam line break if feedwater is isolated both on CHP and on SGLP.
Additionally, the analysis of standard review plan Chapter 15 events for Cycle 9 fuel, (ANF 90-78, submitted to the NRC on October 3, 1990) shows that isolating main feedwater both on CHP and on SGLP is conservative.
A TSCR submitted on June 28, 1989, concerning Shutdown Cooling, also proposed adding a surveillance to Table 4.2.2. If that TSCR is approved prior to this, the surveillance proposed here should be renumbered accordingly.
- 10.
The surveillance requirements for Environmental Monitors, Table 4.1.3 item 6, were requested to be deleted by TSCR submitted on October 13, 1989.
They are not included in the proposed specifications.
16 K.
Deleting 4 surveillance items formerly in Specification 4.1:
- 1.
The requirement to perform a calorimetric when a Flux - AT power comparitor alarm occurs, Table 4.1.1 item 1.b, was deleted. This item is inappropriate, as a Technical Specification requirement, for the following reasons:
- 2.
- 3.
- 4.
It is inappropriate as an SR because it is not a periodic test, and is required only upon particular plant conditions (alarm occurrence);
It is inappropriate as an Action statement because no Completion Time is specified, so the next regularly scheduled daily calorimetric would fulfill the requirement. Also no setpoint is specified for the alarm, so the Action is not required at any particular Flux - AT difference.
The alarm could be adjusted so that the alarm would never occur.
The requirement to do a calorimetric when the Flux-AT alarm occurs is part of the Alarm Response Procedures (ARP 21).
The requirement to test diesel generator auto start initiating circuits, Table 4.1.2 item 11.c, was deleted. This requirement was used to verify operability of the diesel start on turbine trip, and was checked when the manual turbine trip was tested during each turbine startup. The diesel start on turbine trip feature was removed by the facility change which added the new offsite power "safeguards" transformer.
The subject requirement is no longer appropriate; its deletion reduces unnecessary diesel starts.
The surveillance requirements for Emergency Plan Monitors, Table 4.1.3 item 5, were deleted. This SR involves only portable instrumentation located in the Emergency Plan 11Kits 11 which are in various locations for use during emergencies. It is inappropriate to include such a requirement in the Technical Specifications. The requirement for periodic testing will be maintained under administrative control.
The requirement for a Channel Functional Test on the Wide Range Pressurizer Level channels, Table 4.1.3 item 7.c, was deleted as inappropriate because these instruments provide no required automatic action. A level alarm is associated with one wide range channel, but it provides no safety related function.
There is no Channel Functional Test for AMI instruments in STS.
Table A: Other Safety Function Table Changes Existing "Permissible Bypass Condition"
> 10-43 Existing SR or 3.17.4 Item No.
Proposed "Applicable Conditions" Below 10-43 17 I.
- 2.
Instrument Startup Range Rod Position indication Former SR 7
4.1.3.2 4.1.3.3 When associated CROM is capable of rod withdrawal.
- 3.
- 4.
- 5.
- 6.
SIT Level SIT pressure SIRW Tank Temperature Main Feed Flow
- 7.
Main Feed Temp
- 8.
AFW Flow
- 9.
PCS Leakage Detection
- 10.
Pri. Safety Pas Ind Former SR Former SR Former SR Former SR
< 325°F
< 325°F 4.1.2.13 4.1.2.13 4.1.2.17 4.1.3.10 New 13 New 9
- 11.
PORV Pas Ind When PORV i so 10 vlv is closed & its indication is operable
- 12.
PORV Isa Valve When PCS is 11 Pas Ind vented thru 1.3 in2
- 13.
SWS Break Detector
- 14.
Power Comparator
- 15.
Out of Sequence Monitor None None NA 4
2 5
HOT STANDBY and above.
HOT STANDBY and above.
Above 300°F.
Above 15% RATED POWER.
Above 15% RATED POWER.
Above 300°F.
Above 300°F.
Above 300°F.
> 210°F when PORV iso vlv is open or its Pas Ind system is inoperable.
At all times, unless PCS is depressurized & vented iaw Specification 3.1.8.
HOT STANDBY and above.
POWER OPERATION.
>1 rod capable of being withdrawn.
- 16.
BAT Lo Lvl Alm Former SR 4.1. 2.14 HOT STANDBY and above.
- 17.
Excore Det Dev Alm
< 25%
16 Above 25% RATED POWER.
- 18.
ASI Alm
< 25%
17 Above 25% RATED POWER.
- 19.
SDC Suction Interlock Former SR 4.1.3.12 Above 200 psia.
- 20.
PDIL Alm NA 5
HOT STANDBY and above.
- 21.
SFP Area Monitor Former SR 4.1.3.4 When fuel in pool area.
- 22.
Cont Refuel Area Mon Former SR 4.1.3.4 REFUEL OPS w. irradiated fuel in Containment.
18 III. Analysis of No Significant Hazards Consideration The proposed Technical Specification Changes are requested to clarify the intent of the Technical Specifications and to simplify their use.
The proposed changes add operability requirements for newly installed equipment and for equipment whichcurrently has only surveillance requkements; they state spec~fic applicabilities for existing instrumentation requirements which assure the actuated equipment will be available to provide its safety function, but allow maintenance when the equipment is not needed.
Changes A. C, F. G, H. and I are strictly editorial and involve no changes of limitations or requirements, but only page number changes and relocations of limitations and requirements within the Technical Specifications. Therefore, these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a significant reduction in a margin of safety.
Change B, clarification of the definition section, involves no Significant Hazards Consideration, because, while it does alter defined terms used within the requirements and bases of the Technical Specifications, these alterations serve only to clarify the existing definitions or to make them more restrictive.
These changes to the Definitions: a) update the existing definitions to more closely agree with those in STS, b) provide additional requirements (Channel Check and Refueling Boron Concentration), and c) provide consistency with other specifications (Physics Testing).
None of these changes to the definitions involve a relaxation of requirements.
The proposed definitions are effectively the same as, or are more restrictive than, the existing definitions. Therefore, these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a significant reduction in a margin of safety.
Change C is discussed above, with change A.
Change D, rewriting of the ESF settings Specification includes editorial changes, an additional setpoint limitation, and an additional required Action to those already contained in the Technical Specifications.
Each part of the change, as described below, does not involve a significant increase in the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a significant reduction in a margin of safety.
Part 1, rearranging the specification, involves no Significant Hazards Consideration, because it is strictly editorial, simply rearranging the physical presentation of the requirements. It in no way affects limitations or requirements.
Part 2, adding a specific Applicability statement, involves no Significant Hazards Consideration, because the specified applicability is the same as that used in STS and in current Palisades operating practice. This change places existing operating requirements into the Technical Specifications to eliminate an omission.
Part 3, deleting a non-functional feature (the objective statement) which has no counterpart in STS, involves no Significant Hazards Consideration, because the deletion has no effect on either operation of the plant or on interpretation of the Technical Specifications.
19 Change D, rewriting of the ESF settings Specification (continued)
Part 4, specifying a required Action to be taken if the specification is not met, involves no Significant Hazards Consideration, because it imposes an additional required Action to those already contained in the Technical Specifications. The proposed Action is the same as that Action required by STS, and by current Palisades operating practice. This change places existing operating requirements into the Technical Specifications to eliminate an omission.
Part 5, reformatting Table 3.16 and moving some background information to the basis, involves no Significant Hazards Consideration, because it affects no limitations or requirements.
Part 6, adding an Allowable Value for the AFAS, involves no Significant Hazards Consideration, because it imposes a setpoint requirement in addition to those already contained in the Technical Specifications. The proposed requirement is included in STS, and agrees with current Palisades operating practice. The specified Allowable Value agrees with current Palisades safety analyses and instrument settings. This chan~e places existing operating requirements into the Technical Specifications to eliminate an omission.
Part 7 deleting ESF instrument settings related to 1900 psia operating pressure (which is no longer used), involves no Significant Hazards Consideration, because the limitation which required the lower operating pressure has been removed from the Technical Specifications by a prior license amendment.
Change E, rewriting the Instrument Systems LCO section, is mostly editorial. It provides an improved structure and better coordination with the surveillance section.
Each part of the change, as described below, does not involve a significant increase in the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a significant reduction in a margin of safety.
Part 1, editorial changes due to rewriting Specification 3.17, involve no Significant Hazards Considerations because they involve no requirement changes, but only LCO and Action numbering changes, and relocation of requirements within the instrumentation LCOs.
Part 2, specifying Applicabilities for LCOs where none are currently specified, involves no Significant Hazards Considerations, because it assures that instrumentation is available when its associated safety function is required, but allows maintenance or testing when it is not required.
The existing Technical Specifications provide this information only throu~h a list of "Permissible Bypass Conditions".
The proposed applicabilities require each instrument channel to be Operable whenever its safety function or its actuated equipment is required or assumed to function by the safety analysis.
~art 3, specifyiryg,Completion Times for Ac~ions where norye were specified, involves no Significant Hazards Considerations because, it only serves to remove ambiguity with regard to the time allowed for completion of required Actions.
Explicitly specifying completion times makes the resulting specifications more like the Standard Technical Specifications.(STS) than they are currently.
Change E, rewriting the Instrument Systems LCO section (continued}
Part 4, changing the "Shutdown Action" from requiring Cold Shutdown entry to requiring a condition where the LCO does not apply, involves no Significant Hazards Considerations because, it is simply an editorial clarification which makes the resulting specifications agree more closely with the existing Specification 3.0.2.
20 Part 5, changing the allowable bypass setpoint for non-safety related trips from 15% to (effectively} 15 +/- 2%, involves no Significant Hazards Considerations because, it affects only trips which are not assumed to function by the safety analyses.
It provides a setting tolerance which allows both bypass settings to be within specification; they are both actuated by the same bistable amplifier.
Part 6, changing the Required Actions for inoperable AFAS channels, involves no Significant Hazards Considerations because it removes inappropriate Action requirements and replaces them with Actions which agree with the STS and proposed Palisades Action statements for RPS and ESF channels.
The proposed Action statements impose a time limit on operation with one AFAS channel inoperable and prohibit operation with two inoperable.
Part 7, adding a specification for AMI instrument channels, involves no Significant Hazards Considerations because it changes no existing limitations or requirements.
The proposed requirements are the same as those developed for the Improved Standard Technical Specifications.
Part 8, changing the Alternate Shutdown System "Shutdown Action" for consistency within proposed Specification 3.17, involves no Significant Hazards Considerations because, while it extends the completion time allowed to bring the plant to a condition where the Alternate Shutdown System is not required, the proposed completion time is the same as the completion time (existing and proposed} for the RPS and other safety equipment.
The Alternate Shutdown System has less safety impact than the RPS of the ESF instrumentation, so specifying a completion time for the Alternate Shutdown System which is already approved for those more important systems can induce no undue risk.
Part 9, clarifying the usage of the "Minimum Operable Channels" column, involves no Significant Hazards Considerations because. it is an editorial change which alters no requirements.
Part 10, reducing the "Minimum Operable Channels" specification of two instrument functions, involves no Significant Hazards Considerations because, in the case of the Subcooled Margin Monitor, the Action proposed for two inoperable channels is the same as that specified in STS and, in addition, an Action has been specified limiting operation with one channel inoperable to one week (again the same as STS} where no Action is currently required; in the case of the SWS break detector, the equipment is not safety related and the specification of an Action avoids an unnecessary plant shutdown and the associated system transients.
Part 11, including stem position as an acceptable means of PORV position indication, involves no Si~nificant Hazards Considerations because the change requires the Operability of a more positive valve indication channel yet allows reliance on the currently specified channels during maintenance of the newly specified channel.
21 Change E, rewriting the Instrument Systems LCO section (continued)
Part 12, adding LCOs for instrument channels which currently have only a surveillance requirement, involves no Significant Hazards Considerations because it changes no existing limitations or requirements.
Adding Operability and Applicability statements, and specifying required Actions for instruments which currently have none assures that these instruments will be Operable when their function is required, or that operation will only continue if the specified required Actions are accomplished within the specified completion time.
Part 13, adding an Action statement for an inoperable SWS break detector, involves no Significant Hazards Considerations because the Operability of the SWS break detector has no affect on plant safety. Providing an Action statement will, if the SWS break detector should fail during power operation, avoid an unnecessary plant shutdown and the associated system transients.
Changes F, G, H, and I are discussed above, with change A.
Change J, rewriting the Instrument Systems Tests Specification, provides standardized terminology and better coordination with the LCO section.
Each part of the change, as described below, does not involve a significant increase in the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a significant reduction in a margin of safety.
Parts 1 through 5 editorial changes, involves no Significant Hazards Consideration, because they only involve rewriting of existin~ requirements to achieve better correlation with the instrument LCOs, to utilize the standard instrument surveillance definition wherever possible, and to move requirements within Section 4 to group related items together.
Part 6, specific identification of required Area Monitor surveillance, involves no Significant Hazards Consideration, because it assures that all those monitors assumed to function by the accident analyses are subjected to periodic testing.
The proposed specification, along with the addition of Area Monitor LCOs to Section 3, assure Operability of all necessary monitors.
Part 7, extending the surveillance interval for two Accident Monitoring instruments, involves no Significant Hazards Consideration, because it specifies the same interval for testing these instruments as is used in STS.
It also provides uniformity within the associated specification.
22 Chanfie K, deletion of four surveillance requirements, removes three requirements whic test features which are not required by safety analyses or by the Technical Specifications. The fourth deleted requirement is a response to an alarm, rather than a periodic surveillance; this response is currently, and will remain as, part of the plant alarm response procedure.
Each part of the change, as described below, does not involve a significant increase in the probability or consequences of ari accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a significant reduction in a margin of safety.
Part 1, deletion of a requirement to do a Calorimetric upon receipt of a Flux-AT alarm, involves no Significant Hazards Consideration, because it eliminates an inappropriate item from the Technical Specifications.
The Action required by this item remains as the Action required by the plant Alarm Response Procedure.
The item is inappropriate because: Action statements should not be included in the surveillance section; neither completion time nor alarm setpoint is currently specified; the calorimetric completed daily {a sperate surveillance} could be construed to fulfill the subject requirement.
Part 2, deletion of a requirement to verify Diesel Generator starting prior to each startup, involves no Significant Hazards Consideration, because it eliminates an unnecessary DG start {one which is not required by STS}.
The feature which this SR was intended to verify was removed from the plant when the new offsite electrical power source was installed. Deletion of this SR was overlooked at that time.
Part 3, deletion of surveillance testing on portable Radiation Monitors located in the Emergency Plan Kits, involves no Significant Hazards Consideration, because testing requirements for these items will be retained under administrative control. This change disassociates the operability of these instruments from plant operation.
Part 4, deletion of a Channel Functional test on a wide range Pressurizer level alarm, involves no Significant Hazards Consideration, because it removes a requirement to verify operability of an alarm which is not req~ired to be operable.
No similar requirement exists in STS.
23 In summary, Consumers Power Company finds that activities associated with this change request include no significant hazards; and accordingly, a no significant hazards determination per 10CFR50.92(c) is justified. The following summary supports the finding that the proposed change would not:
- 1.
Involve a significant increase in the probability or consequences of an accident previously evaluated.
Only one proposed change could have any effect on the probability of accidents previously evaluated.
Requiring an inoperable RPS or ESF trip unit to be placed in trip, rather than left in bypass, could increase the probability of an inadvertent trip with the consequent possibility of a subsequent loss of decay heat removal.
That increase in the probability of a loss of decay heat removal event is judged to be small; there is a compensating decrease in the probability of an ATWS event which is also judged to be small.
Neither of these changes in probability is judged to be significant. The subject part of the proposed changes is a feature of the Standard Technical Specifications for CE plants.
As discussed above, the proposed changes have little effect on operation of the plant. The proposed changes require more equipment to be Operable, and state explicitly when that the equipment must be Operable and what Actions must be taken if it should become inoperable.
The major effect of the proposed changes is an increase in clarity of the requirements by way of a uniform presentation of LCO, Action, and Surveillance. Changes 16 and 17 do affect operation, but not in such a way as to increase the probability or consequences of a previously evaluated accident nor to create any new kind of accident.
The proposed changes do not effect the availability or reliability of any equipment required to mitigate the effects of a previously evaluated accident.
The specification of specific Instrumentation LCO applicabilities maintains the assurance that the required instrumentation is available to initiate automatic actions and to allow monitoring of plant conditions, while clarifying the conditions under which the instrumentation may be removed from service for maintenance or testing.
Therefore, the proposed changes do not involve a significant increase the probability or consequences of an accident previously evaluated.
- 2.
Create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed changes would not alter the operating conditions of the plant systems, and would not reduce the reliability of any plant equipment.
Therefore, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3.
Involve a significant reduction in a margin of safety.
With the exception of adding an Allowable Value specification for the Auxiliary Feedwater Actuation Signal (AFAS), where none is currently specified, the proposed changes would not affect the setpoints, capacities, or operating limits for any required equipment.
The Allowable Value specified for AFAS is in agreement with the assumptions of the Safety Analyses.
Therefore, the proposed changes do not involve a significant reduction of a margin of safety.
24
==
IV. Conclusion:==
The Palisades Plant Review Committee has reviewed this Technical Specifications Change Request and has determined that while this change could be construed to involve an unreviewed safety question, the change involves no significant hazards consideration. lhis change has been reviewed by the Nuclear Performance Assessment Department. A copy of this Technical Specifications Change Request has been sent to the State of Michigan official designated to receive such Amendments to the Operating License.
CONSUMERS POWER COMPANY To the best of my knowledge, information and belief, the contents of this Technical Specifications Change Request are truthful and complete.
Sworn and subscribed to before me this /~day of ()~
1991.
k_~Lyyj.~
Notary Public
, Michigan My commission expires
/:eANN lVIORSE', NOTARY PUBLlO
- YAN BUREN COUNTY, STATE OF MICH!~N'
_My COMMISSION EXPIRES 06-06*.~4