ML18065A382
| ML18065A382 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/05/1996 |
| From: | Smedley R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18065A383 | List: |
| References | |
| NUDOCS 9601160233 | |
| Download: ML18065A382 (6) | |
Text
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consumers Power POW ERi Nii MICHlliAN"S PROliRESS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 January 5, 1996 U S Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT TECHNICAL SPECIFICATION CHANGE REQUEST - SHUTDOWN COOLING (SOC)
A request for a change to the Palisades Technical Specifications is enclosed.
This change is requested to revise the Shutdown Cooling (SDC) requirements and their bases for Technical Specifications Section 3.1.9.3 prior to the 1996 Refueling Outage. The present Palisades SDC requirements do not contain the flexibility that is currently contained in approved Standard Technical Specifications, NUREG 1432, pertaining to reliance upon a filled reactor cavity as a back-up for decay heat removal capabilities. This lack of flexibility creates an unnecessary financial burden. The proposed revision of the requirements will reduce the 1996 and subsequent refueling outage durations by at least one day each. It is estimated that one day of outage time can cost between $ 250,000 and $ 400,000.
Palisades is in the process of preparing a change request to convert to Standard Technical Specifications (STS). The conversion to STS would achieve the same change to the subject requirements, however it will not be accomplished prior to the 1996 Refueling Outage.
STS (NUREG 1432, Revision 1) Section 3.9.4, "SDC and Coolant Circulation-High Water Level", requires that a minimum of one loop of SDC shall be in operation at Mode 6 with the water level > 23 feet above the top of the reactor vessel flange.
Thus, per the existing approved STS, the second train of SDC could be rendered inoperable for testing or maintenance during this time period. Under similar plant conditions, the Palisades current TS Section 3.1.9.3 requires that one SDC train be in operation with both SDC trains operable. No option exists to take credit for the filled reactor cavity as a functional decay heat removal method to back-up the in-service SOC train.
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An exception does exists in Section 3.1.9.3 to allow a two hour period where one or both SOC trains cah be inoperable as long as certain criteria are met. One of the criteria is that the refueling cavity is full, (water level ;;;:::: 647 feet elevation.) This existing two hour allowed exception is not of sufficient duration to allow the accomplishment of typical refueling outage planned work on the SOC trains.
Two attachments to the enclosure have been included:
- 1)
The Proposed Technical Specifications pages, and
- 2)
The Existing Pages Marked to Show Proposed Changes.
SUMMARY
OF COMMITMENTS This letter completes no commitments, establishes no new commitments, and makes no revisions to existing commitments.
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- a-Richard W Smedley Licensing Manager CC Administrator, Region Ill, USNRC Palisades NRR Project Manager, USN RC NRC Resident Inspector - Palisades Enclosure
e 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 the 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.
Discussion Of Proposed Change:
It is proposed that a section of the existfng Palisades Technical Specifications (TS) dealing with Shutdown Cooling (SOC), Specification 3.1.9.3 and its bases, be revised. The proposed change implements similar requirements contained in Standard Technical Specifications (STS), NUREG 1432.
Section 3.1.9.3 of Palisades TS states:
Specification 3.1.9.3 One SOC train sha11 be in operation providing~ 1000 gpm f7ow through the reactor core, and at least two of the means of decay heat remova7 7isted be7ow sha77 be OPERABLE:
- 1.
SOC Train A consisting of an OPERABLE SOC pump and an OPERABLE heat f7ow path to Lake Michigan.
- 2.
SDC Train B consisting of an OPERABLE SOC pump and an OPERABLE heat f7ow path to Lake Michigan.
App 7 i cab i7 it y Specification 3.1.9.3 app1ies when there is fue1 in the reactor, with PCS Temperature is < 200°F and the PCS 7oops NOT fi77ed.
The present TS require that at least two means of decay heat removal capability shall be operable and the only two choices are the the two trains of SOC.
The proposed change will add a third alternative decay heat removal method, a filled reactor cavity, as a possible choice for one of the two required decay heat removal methods.
This third option will actually function as a back-up to the in-service SOC train since the requirement to maintain~ 1000 gpm flow will still exist. A refueling cavity water level of 647' maintains 23 feet of borated water above the reactor. vessel which coincides with the applicability requirement as stated in STS section 3.9.4..
2 II. Reasons for Change:
The proposed Technical Specification (TS) change, adding a full reactor cavity as an alternative decay heat removal method, will reduce the 1996 and subsequent refueling outage durations by at least one day each.
It is estimated that one day of outage time costs between $250,000 and
$400,000.
The outage duration reductions result from the ability to complete planned maintenance and testing on the SDC trains during the time period that the reactor cavity is full.
The present TS requirements dictate that any lengthy planned work on a SDC train be completed at a different plant configuration where the PCS loops are filled and the Steam Generators are available as a back-up decay heat removal method.
Completing the maintenance and testing on the SDC trains at this point in the refueling outage prevents further progress of start-up activities and causes an extension of the critical path outage schedule.
Palisades is in the process of preparing a change request to convert to STS.
STS section 3.9.4 requires *that one train of SDC be in operation with a full reactor cavity. Thus, the conversion to STS will establish the same change to the subject requirements, however it will not be accomplished prior to the 1996 Refueling Outage.
III. Analysis of No Significant Hazards Consideration Consumers Power Company finds that this proposed Technical Specifications change involves no significant hazards and accordingly a no significant hazards determination per 10CFR50.92(c) is justified. The change implements requirements previousily established and reviewed as part of the STS.
Since this change would not alter any plant operating conditions, safety system settings, or equipment capabilities, and implements the technical content of the Standard Technical Specifications, operation of the facility in accordance with the proposed change cannot: 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 previously evaluated, or involve a significant reduction in a margin of safety.
IV.
Conclusion The Palisades Plant Review Committee has reviewed this Technical Specifications Change Request and has determined that proposing this change does not involve an unreviewed safety question.
Further, the change involves"no significant hazards consideration. This change has been reviewed by the Nuclear Performance Assessment Department.
CONSUMERS POWER COMPANY To the best of my knowledge, the contents of this Technical Specifications change*request, which revises the Shutdown Cooling operational requirements, are truthful and complet~.
By 2 r,rJ_~
T Jflj'I lsino Plant General Manager Sworn and subscribed to before me this !{"}),.,___ day of Alora M. Davis, Notary Public Berrien County, Michigan (Acting in Van Buren County, Michigan)
My commission expires August 26, 19.99 1996.
3
[SEAL]
ATTACHMENT 1 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 TECHNICAL SPECIFICATION CHANGE REQUEST SHUTDOWN COOLING (SOC)
Proposed Pages 2 Pages