ML18065A909
| ML18065A909 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/04/1996 |
| From: | Bordine T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18065A910 | List: |
| References | |
| NUDOCS 9609130148 | |
| Download: ML18065A909 (7) | |
Text
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PfiJW!r POWERING MICHIGAN'S PROGREB Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 September 4, 1996 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT Thomas C. Bordine Manager, Licensing ELECTRICAL TECHNICAL SPECIFICATION CHANGE -ADDITIONAL CHANGES On December 27, 1995, Consumers Power Company submitted a Technical Specification Change Request which would update and clarify the Technical Specification Electrical Power System requirements and their bases. During discussions between Consumers Power Company and the NRC, the NRG reviewer suggested additional changes which would improve the proposed specifications. This letter responds to those suggestions and supplements the December 27, 1995, request.
Revised sets of proposed Technical Specification (TS) pages and bases pages are included as Attachments 1 and 2 to this letter. Additional sets of proposed TS and bases pages, marked to show changes from those submitted on December 27, 1995, are included as Attachments 3 and 4. A listing of NRG reviewer comments and the Consumers Power Company Responses is included as Attachment 5.
As a result of Comment 19, a change is proposed to the TS which is classified as "Less Restrictive". A Less Restrictive change is one which deletes any existing requirement, or which revises any existing requirement resulting in less operational restriction.
As discussed in the response to Comment 24, two changes which were formerly classified as "Relocated" are reclassified as "Less Restrictive". A Relocated change is one which only moves requirements, not meeting the 10 CFR 50.36(c)(2)(ii) criteria, from the TS to the FSAR, to the Operating Requirements Manual, or to other documents controlled under 10 CFR 50.59.
A CMS ENeRGY COMPANY
A No Significant Hazards Analysis covering these three "Less Restrictive" changes is provided below. The other changes to the proposed TS presented in this letter do not affect the classification of changes or the conclusions of the No Significant Hazards analysis provided in our December 27, 1995, TS change request.
2 In addition to the changes made in response to NRC reviewer comments, the following additional revisions have been made to the proposed TS:
A)
The designators for Station Batteries and Battery Chargers have been revised to use the newer designators used in the Palisades equipment data base. For example, station battery D01 changes to ED-01; battery charger D16 changes to ED-16. This change is editorial and does not affect the proposed requirements or the No Significant Hazards Analyses included in our December 27, 1995, letter. The equipment designators are not used in the current Palisades Technical Specifications (CTS).
B)
The Actions for the shutdown LCOs were editorially reworded to enhance their clarity. The wording "initiate the following actions immediately:" was changed to "immediately initiate action to:" in each of the affected Actions (See 3.7.2.A, 3.7.2.B, 3.7.5.A, 3.7.8.A, and 3.7.10.A). This change is editorial and does not affect the proposed requirements or the No Significant Hazards Analyses included in our December 27, 1995, letter. The altered wording appears only in newly proposed LCO Actions. Neither the initially proposed wording nor the clarified wording appears in CTS.
C)
The statement included in surveillance Sections 4.7.1 and 4.7.2 that "Momentary transients outside the specified range do not invalidate a DG load test." has been deleted from Section 4.7.2, where no diesel generator load tests are required. This change is editorial and does not affect the proposed requirements or the No Significant Hazards Analyses included in our December 27, 1995, letter.
D)
The specified tolerance for sequencer timing has been changed from 0.1 seconds to 0.3 seconds. The current TS contain no specific acceptance criterion. The proposed 0.3 second timing limit will assure that the assumptions of both the diesel generator load analyses and the accident analyses are met, without being unnecessarily restrictive. Since the required accuracy of the sequencers is not specified in the CTS, This change does reduce any CTS requirement and does not affect the No Significant Hazards Analyses included in our December 27, 1995, letter.
E)
Proposed surveillance requirement 4. 7.3.5 (10 year cleaning of the Fuel Oil Storage Tank), which was included to emulate the Standard Technical
Specifications (STS), is no longer proposed. Its deletion from STS has been proposed by industry change TSTF-2. Current TS contain no similar requirement, so this deletion from the formerly proposed TS does not represent a change to CTS requirements.
3 During the preparation of responses to the NRC reviewers comments, it was discovered that the discussion of fuel oil transfer pumps contained in our December 27, 1995, submittal (paragraphs 4 and 5 on page 14 of the TS change request) was not entirely correct. Contrary to the discussion in paragraph 4, the current TS do not contain any operability requirements for fuel oil transfer pumps. The only reference to fuel oil transfer pumps in current TS appears in surveillance 4.7.1.e, which requires those pumps to be verified operable each month. Palisades administrative requirements do require at least one fuel oil pump to be operable.
Paragraph 5 states that proposed Action 3.7.1.J requires immediate entry into LCO 3.0.3; the proposed Action had been revised, changing the required actions, but the discussion in the TS change request was not updated. Paragraphs 4 and 5 are revised as follows:
"The existing TS require only surveillance of the fuel oil pumps, and contain no fuel oil transfer pump operability requirement or action statements for the condition when no
- pump is operable.. The existing TS, therefore, place no limitation on operation when one pump is inoperable.
Proposed Conditions 3. 7. 1. G, 3. 7. 1. H, and 3. 7. 1.1 contain requirements for operation with one inoperable fuel oil transfer pump which are not currently in TS and have no equivalent in STS. Proposed Conditions 3. 7. 1. G and 3. 7. 1. H contain requirements which reflect the effects of a specific fuel oil transfer pump being inoperable. Proposed Condition 3. 7. 1.1 requires restoration of one fuel oil transfer pump within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> when both fuel oil transfer pumps are inoperable. These plant specific requirements are necessary because the fuel oil system at Palisades is unlike that for which the STS requirements were conceived. The proposed TS for inoperable fuel oil transfer pumps are more restrictive than those of the existing TS."
Additional discussions of the fuel oil transfer pumps are provided in Attachment 5 as part of the response to Comments 1 through 8.
Analysis of No Significant Hazards Consideration Consumers Power Company finds that these proposed Technical Specifications changes involve no significant hazards and, accordingly, a no significant hazards determination in accordance with 10 CFR 50.92(c) is justified.
Three proposed changes to the Electrical Power Systems TS discussed in this letter are not addressed by the No Significant Hazards Analysis of our December 27, 1995, TS change request. They are addressed below:
- 1)
The first is the change associated with Comment 19, deleting CTS SR 4.7.1.d (a requirement to periodically verify that DG loads do not exceed 750 amps at 2400 volts - the generator continuous rating) from the TS and placing a similar requirement in FSAR. This change replaces change 24 of our 4
December 27, 1995, submittal and is classified as Less Restrictive.
- 2)
The second is change 18 of our December 27, 1995, submittal (Deleting Action 3.7.3.C (Immediately suspend crane operations over irradiated fuel) and Action 3.7.3.D (Immediately suspend operations with a potential for draining the PCS or fuel pool) and placing similar requirements in the Operating Requirements Manual. This change was formerly classified as Relocated, and has been reclassified as Less Restrictive.
- 3)
The third is change 23 of our December 27, 1995, submittal (Deleting SR 4.7.1.c, the DG inspection requirements) and placing a similar requirement in the Operating Requirements Manual (which will be described in the FSAR by reference). This change was formerly classified as Relocated, and has been reclassified as Less Restrictive.
The subject changes are classified as "Less Restrictive" TS changes because the subject requirements will be removed from the TS. For each of these changes, equivalent requirements will be added to the FSAR or to a document referenced in the FSAR (thereby controlled under 10 CFR 50.59) prior to implementation of the TS amendment associated with these changes.
There would be no effect on plant operations from moving a requirement from one controlled document to another. However, a requirement in a document controlled under 50.59 could be changed without prior NRC approval.
The No Significant Hazards Analysis, therefore, addresses the potential for the relocation of a requirement from the TS (controlled by the NRC) to the FSAR or to documents which are described in the FSAR (controlled by the licensee under the limitations of 10 CFR 50.59) to create a Significant Hazards Consideration as discussed in 10 CFR 50.92(c).
Do changes which relocate a requirement from the TS to documents which are controlled under 10 CFR 50.59 involve a significant increase in the probability or consequences of an accident previously evaluated?
5 1 O CFR 50.59 specifically prohibits changes to the facility as described in the safety analysis report, and to procedures described in the safety analysis report "if the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report may be increased". Since the conditions which limit changes performed under 50.59 are more restrictive than the conditions which define changes considered to involve a significant hazards consideration, relocation of a requirement from the TS to the FSAR or to documents which are referenced by the FSAR cannot involve a significant increase in the probability or consequences of an accident previously evaluated.
Do changes which relocate a requirement from the TS to documents which are controlled under 10 CFR 50.59 create the possibility of a new or different kind of accident from any previously evaluated?
1 O CFR 50.59 specifically prohibits changes to the facility as described in the safety analysis report, and to procedures described in the safety analysis report "if a possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report may be created". Since the conditions which limit changes performed under 50.59 are more restrictive than the conditions which define changes considered to involve a significant hazards consideration, relocation of a requirement from the TS to the FSAR or to documents which are referenced by the FSAR cannot create the possibility of a new or different kind of accident from any previously evaluated.
Do these changes which relocate a requirement from the TS to documents which are controlled under 10 CFR 50.59 involve a significant reduction in a margin of safety?
10 CFR 50.59 specifically prohibits changes to the facility as described in the safety analysis report, and to procedures described in the safety analysis report "if the margin of safety as defined in the basis for any technical specification is reduced". Since the conditions which limit changes performed under 50.59 are more restrictive than the conditions which define changes considered to involve a significant hazards consideratioh, relocation of a requirement from the TS to the FSAR or to documents which are referenced by the FSAR cannot involve a significant reduction in a margin of safety.
~
6 Therefore, a no significant hazards determination, in accordance with 10 CFR 50.92(c),
is justified.
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.
SUMMARY
OF COMMITMENTS This letter contains no new commitments or revisions to existing commitments.
Thomas C. Sardine Manager, Licensing CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Attachments
J CONSUMERS POWER COMPANY To the best of my knowledge, the contents of this Technical Specifications change request, which revises the Electrical Power Systems Technical Specifications change request submitted on December 27, 1995, are truthful and complete.
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Manager, Licensing Sworn and subscribed to before me this..yu_ day of ~
w 1996.
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Alora M. Davis, Notary Public Berrien County, Michigan My commission expires August 26, 1999 *
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