Text

Revises 921208 Application for Amend to License DPR-20 & Brings Proposed Specifications Closer to Model Tech Specs, While Retaining Necessary plant-specific Differences & Updating Proposed Pages to Reflect Amends 147 & 149
	ML18058B899
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Site:	Palisades
Issue date:	06/25/1993
From:	Slade G; CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
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Power GB Slade General Manager POWERiNii MICHlliAN"S PRDliRESS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 June 25, 1993 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - TECHNICAL SPECIFICATIONS CHANGE REQUEST - OVERPRESSURE PROTECTION - REVISED PAGES.

Enclosed is a revision to our December 8, 1992 proposed Technical Specifications pages which address GL 90-06 model Technical Specifications, as discussed in a conference call between Tony Hsia and Mohammed Shuaibi, of the NRC staff, and Barry Young, of the Palisades staff. These proposed pages incorporate changes which bring the proposed specifications closer to the model Technical Specifications, while retaining the necessary plant specific differences and update the proposed pages to reflect amendments 147 and 149.

Attachment 1 contains a discussion of each difference between the Palisades proposed Technical Specifications and the model Technical Specifications.

Attachment 2 contains the proposed Technical Specification pages.

Attachment 3 contains the Engineering Analysis which determined the specified PCS vent capability.

Existing Technical Specification pages marked up to show the proposed changes are not included. Proposed pages 3-25a and 3-25b are to replace existing pages of the same numbers; existing page 3-25c is to remain unchanged; proposed pages 3-25d through 3-25g are to be added; and proposed pages 3-Bla, 4-le, and 4-2 are to replace the existing pages of those numbers.

The changes proposed in this letter do not alter the conclusions of the No Significant Hazards Analysis contained in our April 15, 1992 letter on this subject. A copy of this letter has been sent to the State of Michigan.

xS.£/4 Ac__ _

Gerald B Slade General Manager CC Administrator, Region III, USNRC Resident Inspector, Palisades Attachments

(;60088

-- ~g27o~gM~ 6583!g~5 . -J A CMS' ENERGY COMPANY

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 25th day of June 1993.

LeAnn Morse, Notary Public Berrien County, Michigan Acting in Van Buren County, Michigan My commission expires February 4, 1997

ATTACHMENT 1 Consumers Power Company Palisades Plant Docket 50-255 PROPOSED PORV TECHNICAL SPECIFICATIONS Discussion of Differences Between GL 90-06 Model TS and Palisades Proposed TS June 25, 1993 12 Pages

Discussion of Differe~s Between GL 90-06 Model TS an~alisades Proposed TS Model TS 3.4.4:

1} Genera 1 Arrangement:

Format, numbering, and terminology was changed to agree with the balance of Palisades Technical Specifications (TS).

Model TS Actions were reorganized to address PORV flow paths being inoperable, rather than PORVs or block valves being inoperable. This rearrangement was done as a matter of judgement:

a) It addresses the objective of having the ability to provide pressure relief or a decay heat removal flow path, b) It presents the required action in a format similar to that used in other recent Palisades TS change requests.

c) It mimics the new STS, NUREG 1432, in separating the shutdown action from corrective actions.

2} LCO 3.4.4:

GL Attachment A-1 LCO 3.4.4:

"Both power-operated relief valves (PORVs) and their associated block valves shall be OPERABLE."

Palisades proposed LCO 3.1.8.1:

"Two PORV fl ow paths, each consisting of an OPERABLE PORV and an OPERABLE block valve, shall be OPERABLE."

Discussion:

Wording of LCO was changed editorially to address PORV flow paths, rather than just the individual valves.

3} Applicability:

GL Attachment A-1 LCO 3.4.4:

"MODES 1, 2, and 3."

Palisades proposed LCO 3.1.8.1:

"Specification 3.1.8.l is applicable when the temperature of all PCS cold legs is ~ 430°F."

Discussion:

The Applicability was changed to reflect Palisades LTOP analysis and lack of STS "modes".

1

4) e Action for excessive leakage:

GL Attachment A-1 LCO 3.4.4, Action a:

"With one or both PORVs inoperable because of excessive seat leakage, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore* the PORV(s) to OPERABLE status or close the associated block valve(s) with power maintained to the block valve(s); otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ."

Discussion:

Model TS 3.4.4 Action "a." was not included in the proposed TS. It was judged to be inappropriate for the following reasons:

a) Seat leakage does not make the PORVs inoperable; that is, even with leakage in excess of that allowed by the PCS leakage LCO (Palisades LCO 3.1.5, NUREG 1432 LCO 3.4.13) the PORVs could still be manually opened to reduce PCS pressure, in case it is required following an STGR, or to provide "Once Through Cooling, in case of loss of all other methods of decay heat removal. Thus leaking PORVs would still meet the definition of OPERABILITY.

b) The model TS provided neither a PORV leakage limit in the LCO nor a surveillance requirement to determine PORV leakage, so determination of just how much leakage comprised "excessive" leakage would be a matter of judgement.

Palisades TS contain a PCS Leakage LCO (LCO 3.1.5) which contains specified actions to be taken for varying amounts of PCS leakage. In the case of PORV leakage, those actions require:

a) Reducing the leakage to within limits within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , or b) Being in Hot Shutdown (Subcritical above 525°F) within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and being in Cold Shutdown (below 210°F) within the following 24.

These actions are not identical to those of model TS 3.4.4, action a.,

but they are similar. The requirement to maintain power to the block valves is provided by the block valve operability requirement of the LCO, and need not be repeated in the action.

2

5) Action with one Pd~inoperable:

GL Attachment A-1 LCO 3.4.4, Action b:

"With one PORV inoperable due to causes other than excessive seat leakage, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the PORV to OPERABLE status or close its associated block valve and remove power from the block valve; restore the PORV to OPERABLE status within the following 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ."

Palisades proposed LCO 3.1.8.1, corresponding Actions:

"a. With one PORV flow path inoperable:

2. For each inoperable PORV, close the associated block valve within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

3. Restore both PORV flow paths to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

c. If any action required by 3.1.8.1 is not met AND the associated completion time has expired, the reactor shall be placed in HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ."

Discussion:

The feature of model TS 3.4.4.b of removing the power from a block valve closed to isolate an inoperable PORV was omitted for the following reason:

a) Most PORV inoperabilities are administrative involving no actual loss of function, or involving failures which result in the PORV being unable to be opened, rather than in a potential for spurious opening. Failure which would cause a closed block valve to drive open is very unlikely, and for such a failure to occur concurrently with a spurious opening of the associated PORV, within a given 7 day period is even more unlikely.

b) The proposed Action maintains pressure control capability when the PORV is technically inoperable, but still functional.

c) Removing power from a block valve during a PORV inoperability would create the need to operate the block valve to verify operability when power was restored. The section of this discussion dealing with surveillance presents our reasons for not cycling the block valves while at power.

d) The Action requiring being in HOT STANDBY in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months has been omitted, while the requirement to be in HOT SHUTDOWN in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is unchanged. This difference allows a slower rate of power decrease, while still resulting in the same overall time to reach HOT SHUTDOWN. The slower rate of power decrease is necessary to avoid exceeding Axial Shape Index (ASI) limits during shutdowns occurring when core burnup exceeds 5000 MWD/MTU. Rapid shutdowns can be made without exceeding ASI, but require prior planning by Reactor Engineering to co-ordinate control rod and boron insertion for the existing core conditions. Situations which might reguire immediate initiation of a reactor shutdown, such as Technical Specifications Actions, would not necessarily allow time to complete this prior planning.

3

5} Action with two PO. inoperable:

GL Attachment A-1 LCO 3.4.4, Action c:

"With both PORVs inoperable due to causes other than excessive seat leakage, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore at least one PORV to OPERABLE status or close its associated block valve and remove power from the block valve and be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ."

Palisades proposed LCO 3.1.8.l, corresponding Actions:

"b. With two PORV flow paths inoperable:

2. For each inoperable PORV, close the associated block valve within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

3. Restore one PORV flow path to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

c. If any action required by 3.1.8.1 is not met AND the associated completion time has expired, the reactor shall be placed in HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ."

Discussion:

The time allowed to restore one PORV flow path to OPERABLE status, when two paths are inoperable, is proposed as 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months as in model TS action 3.4.4.d, rather than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months in model TS action 3.4.4.c. It appears illogical, for Palisades, where the impact of either event would be similar, to require restoration in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for an inoperable PORV, but in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for an inoperable block valve. By specifying 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for operability restoration, the actions to isolate the inoperable flow paths are completed first, preventing the potential of a LOCA through those paths, and then the restoration is completed. If 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is specified for restoration, there is no reason to specify the isolation actions.

In addition, PORV and block valve inoperabilities, which would be restorable while at power would most often be administrative or electrical. Allowing 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months prior to placing a shutdown transient on the plant might well allow correction of the problem, where 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months might not. This could avoid initiating an unnecessary shutdown.

4

7) Action with one or"o block valves inoperable:

GL Attachment A-1 LCO 3.4.4, Action d:

"With one or both block valves inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore the block valve(s) to OPERABLE status or place its associated PORV(s) in manual control. Restore at least one block valve to OPERABLE status within the next hour if both block valves are inoperable; restore any remaining inoperable block valve to operable status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ."

Palisades proposed LCO 3.1.8.1, corresponding Actions:

"a. With one PORV flow path inoperable:

1. For each inoperable block valve, place the associated PORV control in the "CLOSE" position within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

3. Restore both PORV flow paths to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

b. With two PORV flow paths inoperable:

1. For each inoperable block valve, place the associated PORV control in the "CLOSE" position within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

3. Restore one PORV flow path to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

c. If any action required by 3.1.8.l is not met AND the associated completion time has expired, the reactor shall be placed in HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Discussion:

These two specifications are effectively the same.

8) Note stating 3.0.4 not applicable:

GL Attachment A-1 LCO 3.4.4, Action e:

"The provisions of Specification 3.0.4 are not applicable."

Discussion:

The note "The prov1s1ons of Specification 3.0.4 are not applicable."

which is listed as an ACTION under model TS 3.4.4, was omitted from proposed LCO 3.1.8.1. There is no evident operational necessity for such a note.

5

Model TS 3.4.9.3:

1) General Arrangement:

Format, numbering, and terminology was changed to agree with the balance of Palisades TS.

As in proposed LCO 3.1.8.1, the actions were reorganized to address one or two PORV flow paths being inoperable, rather than one PORV or two PORVs.

The block valves were included in the LCO and actions as was done in proposed LCO 3.1.8.1.

2) LCO 3.4.9.3:

GL Attachment B-1 LCO 3.4.9.3:

11 Two power-operated relief valves (PORVs) shall be OPERABLE with a lift setting of less than or equal to [450] psig. 11 Palisades proposed LCO 3.1.8.2:

"Two PORV fl ow paths, each consisting of an OPERABLE PORV, with a lift pressure less than specified in Figure 3-4, shall be OPERABLE."

Discussion:

Wording of LCO was changed editorially to address PORV flow paths, rather than just the individual PORVs, and to provide consistency between the two related LCOs. The variable setpoint specified is that contained in Amendment 131 to Palisades TS.

3) Applicability:

GL Attachment B-1 LCO 3.4.9.3:

"MODE 4 when the temperature of any RCS cold leg is less than or equal to [275]°F, MODE 5, and MODE 6 when the head is on the reactor vessel and the RCS is not vented through a _ square inch or larger vent."

Palisades proposed LCO 3.1.8.2:

"Specification 3.1.8.2 is applicable when the temperature of any of the PCS cold legs is < 430°F, unless the reactor vessel head is removed. 11 Discussion:

The Applicability was changed to reflect Palisades LTOP temperature requirements. Again, the applicability is the same as that contained in Amendment 131, with the exception for the times when the reactor vessel head is removed added, as in the Generic Letter TS.

The words about the PCS being vented were omitted from the applicability. If these words were included in the applicability, as they were in the Generic letter TS, once the vent path was opened, the LCO would no longer be applicable and the action to periodically verify that the vent path was open would not be required. (Actions are 6

not required '"be completed when the plant applicable conditions.)

co~tions are outside the The acceptable vent capability specified is based on Palisades specific analyses. Palisades current TS specify a 1.3 square inch area, but no basis for this number could be found. It was determined that opening certain flanges on the Palisades PCS would meet the 1.3 square inch area requirement but, due to restrictions in the associated flow path, these flanges would not have provided adequate pressure relief capability. In addition, analyses concluded that for certain unrestrictive flow paths an area smaller than 1.3 square inch could provide sufficient pressure relief. Thus the currently stipulated 1.3 square inch vent area is neither necessary nor sufficient to provide the required protection.

Potential events which could increase PCS pressure during shutdown were analyzed. These events include energy addition from steam generators, pressurizer heaters, decay heat, and inadvertent criticality, and mass additions due to pump starting, letdown isolation, and opening of safety injection tank isolation valves. As discussed in the basis for proposed LCO 3.1.8.2, either automatic opening of the PORVs or manual venting through a vent path of the specified size, together with existing TS requirements, will adequately protect the PCS from pressure transients.

Further background and discussion on the proposed vent specification may be found in item II. A. 2 of our April 15, 1992 TS change request submitted in response to GL 90-06.

4) Action for one PORV inoperable:

GL Attachment B-1 LCO 3.4.9.3, Actions a and b:

"a. With one PORV inoperable in MODE 4, restore the inoperable PORV to OPERABLE status within 7 days or depressurize and vent the RCS through at least a square inch vent within the next 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

b. With one PORV inoperable in MODES 5 or 6, either (1) restore the inoperable PORV to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or (2) complete depressurization and venting of the RCS through at least a _ square inch vent within a total of 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months ."

Palisades proposed LCO 3.1.8.2, corresponding Actions:

"a. With one PORV fl ow path inoperable, restore both PORV fl ow paths to OPERABLE status:

1. within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months with pressurizer water level > 57%, or

2. within 7 days with pressurizer with water level ~ 57%.

b. With two PORV flow paths inoperable, or if any action required by 3.1.8.2a is not met and the associated completion time has expired; depressurize and vent the PCS through a vent path capable of relieving 167 gpm at a PCS pressure of 315 psia within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , . . . "

7

Discussion:

The use of "MODE 4" and "MODES 5 or 6" to differentiate between 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and 7 day completion times (action a and action b) was changed to the use of pressurizer level above or below 57% (maximum level for normal operation). This change was made based on discussion contained in your October 21, 1992 letter. This discussion pointed out that the intended differentiation was whether the plant was "in a water-solid condition" or not.

The 57% level specified for taking credit for a bubble in the pressurizer provides a steam space of approximately 700 cubic feet, out of a total pressurizer volume of 1500 cubic feet, to absorb the additional coolant mass from a pump start or temperature increase. This volume is essentially the same volume as would be available during full power operation. The associated analysis is based on full power operation where the specified volume is adequate to absorb the increased PCS water volume caused by a turbine trip unaccompanied be a reactor trip (although a reactor trip is assumed to occur soon after the turbine trip due to the PCS pressure increase.) The creation of a pressurizer steam bubble, at Palisades, during heat up and the filling of the pressurizer on cooldown do not coincide, exactly, with Mode changes nor with the entry into the conditions which require LTOP protection. The bubble is created, during heatup after the PCS temperature reaches 350°F, and the pressurizer is filled, during cooldown, after shutdown cooling is placed in service, below 300°F. LTOP is required when the PCS is below 430°F.

Specifying a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months completion time when there is less steam space than required for full power operation and a 7 day completion time when that steam space is available should meet the intent of the generic letter and, while not identical to, is comparable to the protection provided by the B&W nitrogen bubble.

5) Action for two PORVs inoperable:

GL Attachment 8-1 LCD 3.4.9.3, Action c:

"With both PORVs inoperable, complete depressurization and venting of the RCS through at least a square inch vent within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ."

Palisades proposed LCD 3.1.8.2, corresponding Actions:

"b. With two PORV flow paths inoperable, or if action required by 3.l.8.2a is not met and the associated completion time has expired; depressurize and vent the PCS through a vent path capable of relieving 167 gpm at a PCS pressure of 315 psia within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , . . . "

Discussion:

With the exception of the specified vent area, which is discussed above, these two specifications are essentially the same.

8

6) Action to verify rlired vent path is open:

GL Attachment B-1 LCO 3.4.9.3, Action d:

"With the RCS vented per ACTIONS a, b, or c, verify the vent pathway at least once per 31 days when the pathway is provided by a valve(s) that is locked, sealed, or otherwise secured in the open position; otherwise, verify the vent pathway every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ."

Palisades proposed LCO 3.1.8.2, corresponding Actions:

"b. With two PORV flow paths inoperable, or if action required by 3.l.8.2a is not met and the associated completion time has expired: depressurize and vent the PCS through a vent path capable of relieving 167 gpm at a PCS pressure of 315 psia within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , and

1. When the pathway is through any valve that is not locked, sealed, or otherwise secured in the open position, verify the vent pathway is open at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , or

2. Otherwise, verify that the vent pathway is open at least once per 31 days."

Discussion:

These specifications are effectively the same.

7) Action requiring reporting of PORV actuation:

GL Attachment B-1 LCO 3.4.9.3, Action e:

"In the event the PORVs or the RCS vent(s) are used to mitigate an RCS pressure transient, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 30 days. The report shall describe the circumstances initiating the transient, the effect of the PORVs or RCS vent(s) on the transient, and any corrective action necessary to prevent reoccurrence."

Discussion:

The reporting requirement of model TS 3.4.9.3, Action e is redundant to that of 10 CFR 50.73{a){2){iv) for PORV actuation. The chance of manually actuated vent valves, located in the containment, being used to mitigate a PCS pressure transient is extremely remote. Therefore no TS action is proposed.

8) Note stating 3.0.4 not applicable:

GL Attachment B-1 LCO 3.4.9.3, Action f:

"The provisions of Specifitation 3.0.4 are not applicable."

Palisades note following proposed LCO 3.1.8.2:

"Note: The provisions of Specification 3.0.4 are not applicable."

Discussion:

These two specifications are the same.

9

.. ' ~

Model TS Surveillance Requirements:

1) Surveillance which cycles PORVs:

GL Attachment A-1 SR 4.4.4.1:

"In addition to the requirements of Specification 4.0.5, each PORV shall be demonstrated OPERABLE at least once per 18 months by:

a. Operating the PORV through one complete cycle of full travel during MODES 3 or 4, and" Palisades proposed SR 4.1.1, corresponding parts:

11 In addition to the requirements of Specification 4.0.5, each PORV flow path shall be demonstrated OPERABLE by:

3. When PORV flow path is required to be OPERABLE by Specification 3.1.8.1:

(a) Performing a complete cycle of the PORV with the plant above COLD SHUTDOWN at least once per 18 months. 11 Discussion:

These two specifications are effectively the same.

3) Surveillance which specifies a Channel Calibration:

GL Attachment A-2 (Westinghouse plants) SR 4.4.4.1.c 11 In addition to the requirements of Specification 4.0.5, each PORV shall be demonstrated OPERABLE at least once per 18 months by:

c. Performing a CHANNEL CALIBRATION of the actuation instrumentation."

Palisades proposed SR 4.1.1, corresponding parts:

11 In addition to the requirements of Specification 4.0.5, each PORV flow path shall be demonstrated OPERABLE by:

2. Performance of a CHANNEL CALIBRATION on the PORV actuation channel at least once per 18 months. 11 Discussion:

These two specifications are effectively the same.

10

4) 'surveillance which~cles the block valves:

GL Attachment A-2 (Westinghouse plants) SR 4.4.4.2:

"Each b1ock va 1ve sha 11 be demonstrated OPERABLE at 1east once per 92 days by operating the valve throu~h one complete cycle of full travel unless the block valve is closed in order to meet the requirements of ACTION b, or c in Specification 3.4.4."

Palisades proposed SR 4.1.1 corresponding parts:

"In addition to the requirements of Specification 4.0.5, each PORV flow path shall be demonstrated OPERABLE by:

3. When PORV flow path is required to be OPERABLE by Specification 3.1.8.1:

(b) Performing a complete cycle of the block valve prior to heatup from COLD SHUTDOWN, if not cycled within 92 days."

Discussion:

Surveillance 4.4.4.2 of GL Attachment A-2 was altered to eliminate the cycling the block valves while at power. Since the safety analyses take no credit for PORV operation when the plant is at power, Palisades has always operated with the block valves closed to ensure against leakage and a possible LOCA. Opening a block valve with the PCS pressurized can, and has, caused momentary opening of the associated PORV. When a block valve is opened prior to entering the LTOP region during a cooldown, it is jogged slightly off its closed seat. Once the down stream pressure has equalized, the block valve is opened fully. Even with this precaution, the associated PORV has, on occasion, cycled in response. The potential for PORV opening, coupled with the very large size of PORVs installed at Palisades, make cycling the block valves, with the plant at power, unacceptable.

5) Surveillance which does not apply to Palisades:

GL Attachment A-2 (Westinghouse plants) SR 4.4.4.1:

"In addition to the requirements of Specification 4.0.5, each PORV shall be demonstrated OPERABLE at least once per 18 months by:

b. Where applicable, operating solenoid air control valves and check valves on associated air accumulators in PORV control systems through one complete cycle of full travel for plants with air operated PORVs . . . "

GL Attachment A-2 (Westinghouse plants) SR 4.4.4.3:

"The emergency power supply for the PORVs and block valves shall be demonstrated OPERABLE at least once per 18 months by:

a. Manually transferring motive and control power from the normal to the emergency power bus, and

b. Operating the valves through one complete cycle of full travel."

Discussion:

Surveillance requirements 4.4.4.1.b and 4.4.4.3 do not apply to Palisades, which is neither equipped with air-operated PORVs or emergency PORV power supplies nor intends to install them.

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6) .Surveillance to de~nstrate.PORV Operability for LT,LCO:

GL Attachment B-1 SR 4.4.9.3:

"Each PORV shall be demonstrated OPERABLE by:

a. Performance of an ANALOG CHANNEL OPERATIONAL TEST, but excluding valve operation, at least once per 31 days; and

b. Performance of a CHANNEL CALIBRATION at least once per 18 months; and

c. Verifying the PORV isolation valve is open at least once per 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ."

Palisades proposed SR 4.1.1, corresponding parts:

"In addition to the requirements of Specification 4.0.5, each PORV flow path shall be demonstrated OPERABLE by:

2. Performance of a CHANNEL CALIBRATION on the PORV actuation channel at least once per 18 months.

4. When the PORV flow path is required to be OPERABLE by Specification 3.1.8.2:

(a) Performance of a CHANNEL FUNCTIONAL TEST on the PORV actuation channel, but excluding valve operation, at least once per 31 days.

(b) Verifying the associated block valve is open at least once per 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Discussion:

These specifications are effectively the same.

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ML18058B899

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