ML18064A734
| ML18064A734 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/27/1995 |
| From: | Haas K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18064A735 | List: |
| References | |
| NUDOCS 9505050214 | |
| Download: ML18064A734 (3) | |
Text
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I consumers Power l'OWERINli Ml(lllliAN'S l'ROliRE55 Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 April 27, 1995
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Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT KurtM. Haas Plant Safety and Licensing Director TECHNICAL SPECIFICATIONS CHANGE REQUEST - SAFETY VALVE SETTING LIMITS RESPONSE TO A REQUEST FOR ADDITIONAL INFORMATION In a Request for Additional Information (RAI) dated April 11, 1995, the NRC requested that Consumers Power Company provide additional information supporting the action statements for inoperable safety valves in proposed Specifications 3.1.7 of our Technical Specification change request of January 3, 1995.
Our proposal was to require resetting of the safety valves only if they were removed from the piping for maintenance or testing. The RAI requested that we either provide justification for not resetting the valves by demonstrating that continued drift beyond the +/-33 range would be acceptable or, alternatively, propose that the valves always be reset to within +/-13 after any action that reveals that they exceed the +/-13 criterion prior to returning them to service.
It was our intent to always reset the valves to within +/-13 after they were discovered to be out of that range.
It is Palisades practice to remove both primary and secondary relief valves from the piping for testing. This testing would be the only means typically available to provide information about the actual valve settings.
Upon receiving the RAI, it was realized that since the practice of removing the valves from the piping for periodic testing is not a Technical Specification requirement and is not the practice at all nuclear power plants, that the proposed wording did not necessarily require resetting after any testing which showed the valves to be beyond the +/-13 criterion as had been intended.
The attachment to this letter contains revised pages with the subject wording altered to require resetting to within 13 after any valve testing or maintenance which could affect the setpoint prior to returning the valves to service.
The intent of the proposed change and the conclusions of the No Significant Hazards analysis remain unchanged.
The RAI also asked that we provide justification with regard to the reasons for the change in time limits as well as the basis for acceptability of the completion times of the proposed action statements.
One purpose of the proposed TS change is to update the structure of the affected sections of the TS.
There is no action statement associated with the existing Specification 3.1.7, therefore discovery that the specification was not met
. would result /"i;l{'N'~.~.nto Specification 3.0.3.
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9505050214 950427 PDR ADOCK 05000255 p
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Since newer technical specification structure and usage dictates that each LCO requirement should have a corresponding action statement, an action statement requiring plant shutdown was included in each of the proposed specifications 3.1.7.1 and 3.1.7.2. That action specified that, if one or more required safety valve was inoperable, the reactor 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 in cold shutdown within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
These proposed times differ from those in Specification 3.0.3, but are identical to those specified for shutdown actions in specifications adopted in recent amendments.
These shutdown actions and their associated completion times were first proposed in the change request which resulted in Amendment 162, a rewrite of the entire Instrumentation section of the TS.
Both the actions and the times were taken from the former (pre-amendment 162) reactor protective system specification.
In addition to the proposed Specifications 3.1.7.1 and 3.1.7.2, Specifications 3.1.2, 3.1.8.1, and all sections of 3.17 utilize these actions and completion times.
The existing requirements for an inoperable safety valve, under Specification 3.0.3, are to be in hot standby within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> (one hour to initiate action and hot standby within the next 6); in hot shutdown within 13 (the following 6); and in cold shutdown within 37 (the subsequent 24).
The proposed actions are to be 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 in cold shutdown within 48.
The proposed requirements allow an additional 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> to reach cold shutdown.
Since, when PCS temperature is below 430°F, PCS overpressure protection would be provided by the PORVs (Specification 3.1.8.2) and secondary pressure would be well below the relief settings (saturation for 430°F is about 335 psig), the slight relaxation in the cold shutdown completion time has no significant impact on safety.
The use of consistent shutdown actions and completion times throughout the TS does, however, make it significantly easier for operations personnel to utilize the Technical Specifications.
SUMMARY
OF COMMITMENTS This letter contains no new commitments or revisions to former commitments.
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Kurt M. Haas Director, Plant Safety & Licensing CC Administrator, Region III, USNRC Resident Inspector, Palisades Attachments
CONSUMERS POWER COMPANY To the best of my knowledge, the contents of this Technical Specifications change request, addressing primary and secondary safety valve settings, are truthful and complete.
By ~
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Robert A. Fenech, Vtce President Nuclear Operations Sworn and subscribed to before me this ::!1""- day of ~Zt.L 1995.
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Norma Jean FWler, Notary Public Van Buren County, Michigan My commission expires May 14, 1998