Text

Safety Evaluation Supporting Amend 180 to License DPR-20
	ML18065B241
Person / Time
Site:	Palisades
Issue date:	04/29/1998
From:	; NRC (Affiliation Not Assigned)
To:	;
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ML18065B242	List: ML18065B241;
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	NUDOCS 9805110013
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 180 TO FACILITY OPERATING LICENSE NO. DPR-20 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET NO. 50-255

1.0 INTRODUCTION

By letter dated December 27, 1995, as supplemented by letters dated September 4, October 18, and November 26, 1996, June 27 and November 21, 1997, and January 29 and April 10, 1998, Consumers Energy Company (the licensee) requested an amendment to the Technical Specifications (TS) appended to Facility Operating License No. DPR-20 for the Palisades Plant. The proposed amendment would revise TS requirements and associated bases regarding the electrical power systems to closely emulate the Standard Technical Specifications for Combustion Engineering Plants, NUREG-1432, Revision 1 (STS).

As a result of discussions with the staff, the licensee submitted revised TS pages and bases pages on September 4, 1996. On November 26, 1996, the licensee responded to a staff request for additional information (RAI) dated November 4, 1996, related to diesel generator (DG) support systems. The licensee provided additional information and revised TS pages to support completion of the review of the change request by letter dated June 27, 1997. The change request had proposed relocating one TS requirement to the final safety analysis report (FSAR) and several TS requirements to the Operating Requirements Manual (ORM). The licensee stated in the June 27, 1997, letter that these requirements had been duplicated in the FSAR and ORM. The licensee revised FSAR Section 12.3.3 to incorporate the ORM by reference. FSAR Section 12.3.3 states:

The ORM contains operating requirements, operational limits, and testing requirements which are in addition to those in the technical specifications. Some of these requirements were formerly in the technical specifications, but were relocated to the ORM because they did not meet the criteria of 10 CFR 50.36 for retention in the technical specifications.

The ORM will be revised in the same manner as the FSAR. Also, on November 21, 1997, the licensee responded to the staff's RAI dated November 13, 1997, related to performing certain DG surveill~hces during power operation. The January 29, 1998, letterrequested that implementation of the amendment be required within 60 days following completion of the 1998 refueling outage, but no later than October 2, 1998. The outage is currently scheduled to be completed on June 2, 1998. The April 10, 1998, letter documented completion of procedure reviews committed to in the licensee's November 21, 1997, letter.

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The June 27 and November 21, 1997, and January 29 and April 10, 1998, letters provided additional clarifying information within the scope of the original Federal Register notice and did not change the staff's initial proposed no significant hazards considerations determination.

2.0 EVALUATION Section 182a of the Atomic Energy Act (Act) requires that applicants for nuclear power plant operating licenses state TS and that the TS be included as a part of the license. The Commission's regulatory requirements related to the content of TS are set forth in 10 CFR 50.36. That regulation requires that the TS include items in five specific categories, including (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls. However, the regulation does not specify the particular requirements to be included in a plant's TS.

The rule specifies that limiting conditions for operation (and associated surveillances) are to be included in a plant's TS if the item meets one or more of the following criteria: (1) an installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary, (2) a process variable, design feature, or operating restriction that is an initial condition of a design-basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier, (3) a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design-basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier, or (4) a structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

The staff's evaluation of the licensee's proposed TS changes follows. Section numbers correspond to the section numbers of the licensee's discussion of proposed changes enclosed with its December 27, 1995, submittal.

2.1 Existing Applicability and Objective Statements Deleted The licensee proposed to delete applicability and objective statements from Sections 3. 7 and

4. 7, indicating that these statements are redundant to the limiting conditions for operation (LCOs) and, therefore, serve no purpose. The wording of Sections 3.7.1and3.7.3 specify the applicable. conditions; the proposed LCOs have applicability statements equivalent to those in the STS. The licensee considered this to be an administrative change.

On the basis of its review, the staff agrees with the licen.see that this change is administrative in nature and hence is acceptable.

2.2 LCO Applicable Conditions Changed to Match the STS The licensee stated that the LCOs of the existing Palisades TS are divided according to

whether they are above or below 300 °F. The LCOs for the STS are divided by Mode.

Modes 1, 2, 3, and 4 are termed "operating" and Modes 5 and 6 are "shutdown." The licensee proposed to change the Palisades TS to be consistent with the STS.

The licensee considered this change to be more restrictive because it proposes requiring two trains of electrical power equipment to be operable when the plant is between 300 ° F (the minimum temperature at which it is currently required) and 210 °F (the upper limit of cold shutdown for Palisades), when only a single train is required by the existing TS..

On the basis of its review, the staff finds that this change will continue to ensure that equipment necessary for safe operation of the plant will be required to be operable and is consistent with the STS; therefore, this change is acceptable.

2.3 Offsite AC Source LCO Revised The existing LCOs 3. 7.1 a and 3. 7.1 b appear as item a. of LCO 3. 7.1, "AC Sources -

Operating," in the proposed TS. The equipment required by existing TS 3.7.1a and 3.7.1b is unchanged from the originally issued Palisades TS, which require that start-up transformer 1-2 and station power transformer 1-2 be operable. These two transformers and their associated circuits were the only offsite sources then available for the Class 1 E 2400-volt buses. Since that time an additional fully capable and qualified offsite source, "safeguards transformer 1-1,"

has been added. The wording of the proposed requirement, which is equivalent to the STS requirement, is more general than the existing LCO. It specifies two qualified offsite sources but does not identify them by equipment identifier. The revised wording would allow substitution of the safeguards transformer, installed subsequent to issuance of the original TS, for the currently specified station power transformer as one of the acceptable required sources.

On the basis of its review, the staff finds that although this change is less restrictive than the current Palisades requirements because it is less specific about the required equipment, the proposed change would continue to require two operable qualified offsite sources as is currently

. required by the existing TS and is consistent with the STS. Therefore, the proposed change is acceptable.

. 2.4 Buses Added to Distribution Systems LCO Existing LCOs 3.7.1c through 3.7.1g appear as LCO 3.7.9,* "Distribution Systems - Operating,"

in the proposed TS. The required electrical distribution equipment is listed in Table 3.7.9-1. All of the equipment currently required by 3.7.1c through 3.7.1g is included in Table 3.7.9-1.

Additional motor control centers have been included in the list of required electrical distribution equipment. The licensee considered this change to be more restrictive because it proposes requiring additional equipment to be operable in order to meet the LCO.

On the basis of its review, the staff finds that this change would continue to require sufficient operable electrical distribution equipment to assure safe plant operation and is consistent with the requirements of the STS. Therefore, the staff finds the proposed change to be acceptable.

2.5 Battery Charger LCO The existing LCO 3.7.1h appears as LCO 3.7.4, "DC Sources - Operating," in the proposed TS.

The proposed LCO requires battery chargers 015 and 016 to be operable. The existing requirement is "at least one charger on each bus," which allows operation with either charger 015 or 017 operable for one battery and either 016 or D18 for the other battery.

Palisades has two chargers for each battery, one powered from the associated ac power distribution train and the other powered from the opposite train. The licensee stated that the cross-connected battery chargers provide additional assurance that de control power and preferred ac power would be available during disturbances in the ac supply. Similarly, redundant de power would be available if both chargers for one de bus were operated in parallel. Existing TS 3.7.2h and the proposed TS 3.7.4.B (discussed in Section 2.13, below) take advantage of this redundant supply by requiring that both chargers be operated when a battery is inoperable.

If, however, only a cross-connected charger were operable for one station battery, the loss of a diesel generator (DG) concurrently with a loss of offsite power would leave one safeguards train without ac motive power and the other train dependent on battery power alone for its de control power. If a charger were not restored before the battery was depleted, about 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , neither safeguards train would be operable. A more restrictive LCO, disallowing continuous operation with either directly connected charger inoperable, was therefore proposed.

The advantages of the Palisades configuration are reflected in the existing TS requirements, which allow a 24-hour allowed outage time (AOT) for an inoperable station battery if both chargers on the affected bus are in operation. The disadvantages are addressed by the proposed requirement that continuous operation be allowed only if both directly connected chargers are operable. Appropriate required actions and completion times have been proposed for the inoperability of one required charger. The 7-day AOT in proposed Action 3.7.4.A (discussed in Section 2.12, below) for a required battery charger when a cross-connected charger is in service was chosen because the condition is less limiting than an inoperable DG, which has a 7-day AOT. The licensee considered this change to be more restrictive because it does not allow continuous operation when a directly connected charger is inoperable.

On the basis of its review, the staff finds the proposed change to be an improvement over the existing requirements. The 7-day completion time takes into account the capacity and capability of the remaining available power sources and allows a reasonable time to evaluate and repair the affected charger. Therefore, the proposed change is acceptable.

2.6 Onsite AC Sources LCO The existing LCO 3. 7. 1 i DG operability requirements appear as item b. of LCO 3. 7.1, "AC Sources - Operating," in the proposed TS. The requirement for 2500 gallons of fuel in each DG day tank would be moved to proposed Surveillance Requirement (SR) 4.7.1.5 (discussed in Section 2.29, below). The requirement for fuel in the underground storage tank would be moved to proposed SR 4.7.3.1 (discussed in Section 2.20, below).

On the basis of its review, the staff finds that this change is equivalent to the current requirements in that it continues to require two operable, qualified onsite sources as is currently required by the existing TS and is consistent with the STS. Therefore, the proposed change is acceptable.

2. 7 Switchyard Power LCOs Relocated The existing LCOs 3. 7.1 j and 3. 7.1 k contain requirements for operability of switchyard de and ac power systems. The switchyard de control power systems are used to control switchyard breakers and to provide protective relaying functions for the switchyard itself.and the incoming transmission lines. The loss of switchyard control power would not cause a loss of offsite power. Switchyard control power is not used to control any of the onsite power supply functions. The switchyard ac power supplies the air compressors associated with the air-operated switchyard breakers. The licensee stated that these switchyard power requirements do not meet the criteria in 10 CFR 50.36(c)(2)(ii) for inclusion in TS and would be relocated to the ORM. By letter dated June 27, 1997, the licensee stated that the requirements had been incorporated into the ORM.

These requirements are not related to detection or indication of reactor coolant pressure boundary degradation; are not process variables, design features, or operating restrictions that are initial conditions of a design-basis accident or transient analysis; are not part of a primary success path to mitigate a design-basis accident or transient; and have not been shown by operating experience or probabilistic ris.k assessment to be significant to public health and safety. Therefore,.they do not meet the 10 CFR 50.36(c)(2)(ii) criteria and are not required to be in TS. The requirements have been incorporated into the Palisades ORM, which has been incorporated by reference into the FSAR. Sufficient regulatory controls exist under 1 O CFR 50.59 to ensure that any future changes to the requirements that constitute an unreviewed safety question will be subject to NRG review and approval priot to implementation. Therefore, the proposed deletion of these requirements is acceptable.

2.8 Bus 1-E LCO Relocated The existing LCO 3. 7.11 requires-2400 volt Bus 1-E to be operable when the plant is above 300 °F. There are three 2400-volt buses in the ac distribution system. Buses 1-C and 1-D are Class 1 E buses and supply 2400-volt engineered safeguards loads. Bus 1-E is not considered Class 1 E and does not supply any safeguard loads. Bus 1-E cannot be supplied from either DG. Bus 1-E was apparently included in the original Palisades TS because it supplies pressurizer heater transformer number 15 (the other transformer, number 16, is supplied by Bus 1-D). Since the initial is were issued, a plant modification has been made to provide an alternate supply to pressurizer heater transformer 15 from Bus 1-C. The licensee stated that Bus 1-E does not meet the criteria of 10 CFR 50.36(c)(2)(ii) and the requirement to have Bus 1-E operable would be relocated to the ORM. By letter dated June 27, 1997, the licensee stated that the requirements had been incorporated into the ORM.

These requirements are not related to detection or indication of reactor coolant pressure boundary degradation; are not process variables, design features, or operating restrictions that are initial conditions of a design-basis accident or transient analysis; are not part of a primary

. success path to mitigate a design-basis accident or transient; and have not been shown by operating experience or probabilistic risk assessment to be significant to public health and safety. Therefore, they do not meet the 10 CFR 50.36(c)(2)(ii) criteria and are not required to be in TS. The requirements have been incorporated into the Palisades ORM, which has been incorporated by reference into the FSAR. Sufficient regulatory controls exist under 10 CFR 50.59 to ensure that any future changes to the requirements that constitute an unreviewed safety question will be subject to NRC review and approval prior to implementation. Therefore, the proposed deletion of these requirements is acceptable.

2.9 General Shutdown Action Statement Revised Existing Action Statement 3. 7.2 is, without its subparagraphs, a requirement to shut down the plant if the other required actions {prescribed in its subparagraphs) are not completed within the specified time. An action statement equivalent to existing TS 3.7.2 appears as the last, or next to last, action statement of each proposed LCO which is applicable above cold shutdown (proposed LCO 3.7.1 Required Actions J.1 and J.2, proposed LCO 3.7.4 Required Actions C.1 and C.2, proposed LCO 3.7.7 Required Actions 8.1 and 8.2, and proposed LCO 3.7.9 Required Actions D.1 and D.2). The licensee considered these proposed requirements to be equivalent to the existing requirements. The licensee considered this change to be administrative because it only rewords an existing requirement and moves it within the TS.

. On the basis of its review, the staff finds this change to be administrative and hence acceptable.

2.10 Required Actions for Inoperable Offsite Sources Revised The existing Actions 3. 7.2a and 3. 7.2b allow 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore an inoperable required offsite circuit (station power transformer 1-2 or start-up transformer 1-2), provided that the operability of both DGs is demonstrated immediately. In addition, continued operation beyond the 24-hour AOT is allowed with start-up transformer 1-2 inoperable if a report with an outline of the plans for prompt restoration of the transformer is sent to the NRC.

The licensee has proposed action, in TS 3.7.1.A, to allow 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore an inoperable required offsite circuit, provided that a verification of proper breaker alignment and availability of power to the required operable circuit (in accordance with proposed SR 4. 7.1.1) is made within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter. The proposed change also deletes the requirement to immediately demonstrate operability of the DGs.

The staff finds that the inoperability of an off site circuit would not affect the operability of a DG, so there is no need to test start the DGs. Although with one offsite circuit inoperable the reliability of the offsite system is degraded and the potential for a loss of offsite power is increased, the staff believes that the remaining operable offsite circuit and DGs are adequate to supply electrical power to the onsite Class 1 E distribution system. Also, the licensee did not propose to retain the option to continue operation beyond the AOT with an inoperable required offsite circuit if a report is submitted.

On the basis of its review, the staff finds this change would continue to provide sufficient operable offsite and onsite sources to supply the onsite Class 1 E distribution system and ensure continued safe plant operation. The AOT extension from 24 to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is consistent with industry operating experience as reflected in the STS. Therefore, the staff finds the proposed change to be acceptable.

2.11 Reguired Actions for Inoperable Distribution Buses Revised Existing Action Statements 3.7.2c through 3.7.2g provide an AOT of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for an inoperable distribution bus, provided there are no inoperable safety feature components associated with the redundant bus. The proposed actions, 3.7.9.A, 3.7.9.B, and 3.7.9.C, provide the same AOT. The limitation that there be no inoperable safety features on the redundant bus is accomplished by proposed Action 3.7.9.E.

Proposed Action 3.7.9.E differs from Action 3.8 9.E of the STS. The STS contains a requirement for a Safety Functions Determination Program (located in STS Admil"!istrative Controls Section 5.5.15) to provide assurance that entry into the conditions *of two or more

-separate LCOs does not result in the loss of a safety function. That is the intent of the prohibition in existing Actions 3.7.2c through 3;7.2g against inoperable safety feature components on a redundant bus. Until a Safety Functions Determination Program is implemented at Palisades, the assurance that the AOT for an inoperable distribution bus does not allow continued operation with a loss of a safety function will be provided by proposed Action 3.7.9.E, which requires immediate entry into TS 3.0.3 for any inoperable distribution subsystem resulting in a loss of safety function. The licensee considered this change to be administrative because it proposes the same actions and AOTs as the existing TS, merely moving them within the TS.

On the basis of its review, the staff agrees with the licensee that this change is administrative and hence acceptable.

2.12 Reguired Actions for Inoperable Charger The licensee proposed new required Actions A.1 and A.2 in proposed TS 3.7.4 to be taken if one of the required battery chargers becomes inoperable. The first required action, "Place the cross-connected charger for the affected battery in service; immediately," is implied by existing TS 3. 7.1 h, which requires one charger per bus to be operable. The second required action is new and places an additional restriction on operation: "Restore the required charger to OPERABLE status; within 7 days." The existing TS allows unlimited continued operation with a single charger operable ~n each bus, regardless of the source of power to that charger.

Additional discussion of the battery and its charging circuits is provided in Section 2.5, above.

On the basis of its review, the staff finds that this requirement is unique to Palisades, which has two identical chargers per battery. These chargers will be verified operable by proposed SR 4.7.4.6 (discussed in Section 2.29, below). The staff finds that this change imposes an additional restriction on operation that provides additional assurance of adequate onsite de power availability. Therefore, the staff finds this change to be an improvement on the existing requirement and hence acceptable.

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2.13 Required Actions for Inoperable Battery The licensee stated that existing Action 3.7.2h allows continued operation for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months with one station battery inoperable, provided both associated battery chargers are placed in operation.

This requirement is rewritten as Action 3.7.4.B. The licensee stated that no change in requirements was proposed. Additional discussion of the battery and its charging circuits is provided in Section 2.5, above.

In response to a staff inquiry, the licensee stated that two chargers can supply all required de loads during an accident. The licensee considered this change to be administrative because it proposes the same actions and AOT as the existing TS, merely moving them within the TS.

On the basis of its review, the staff finds this change to be administrative and hence acceptable.

2.14 Required Actions for Inoperable Diesel Generator (DG)

Existing Action 3.7.2i allows continued operation.with one DG inoperable for 7 days (total for both DGs) in any month provided: (1) the other DG is started to verify operability and then shut down with the controls left in the automatic mode; and (2) no inoperable engineered safety feature components are associated with the operable DG. Proposed Action 3.7.1 8.4 provides the same AOT of 7 days (total for both DGs) during any month. As in the STS, the requirement to test-start the DG, contained in proposed Action 3.7.1 8.3, is modified to allow the. alternative of verifying that the other DG is not inoperable due to common-cause failure, The licensee stated that the existing requirement to place the DG controls in automatic is inherent in the LCO requirement for an operable DG, therefore, this requirement is not explicitly stated in the proposed actions.

The requirement that there be no inoperable engineered safety feature components associated with the operable DG is modified to match the comparable action of the STS. Proposed Action 3.7.1 8.2 allows continued operation for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months with both an inoperable DG and an inoperable safety feature component associated with the operable DG. This condition does not lead to a loss of function, as would the simultaneous inoperability of a distribution bus and component associated with the opposite bus, because offsite power is available; therefore continued operation for a limited period is justified. The proposed time and action are identical to those in the STS.

On the basis of its review, the staff finds that the proposed change would continue to provide assurance of adequate electrical power to the onsite Class 1 E distribution system while ensuring no loss of safety function has occurred. The 4-hour completion time for both an inoperable DG and an inoperable safety feature is acceptable based on the availability of offsite power *and the low probability of an accident occurring during this brief period and is consistent with the STS. Therefore, the proposed change is acceptable.

2.15 Relocation of Actions Associated With Relocated LCOs The licensee stated that existing Actions 3.7.2j, 3.7.2k, and 3.7.2m are associated with switchyard control power LCOs 3.7.1j and 3.7.1k (discussed in Section 2.7, above) and are proposed to be relocated to the ORM with these LCOs. Action 3. 7.21 is associated with non-Class 1E 2400-volt Bus 1-ELCO 3.7.11 (discussed in Section 2.8, above) and is proposed to be relocated to the ORM with this LCO. By letter dated June 27, 1997, the licensee stated that the requirements had been incorporated into the ORM.

As-noted in Sections 2. 7 and 2.8, above, these requirements do not meet the 10 CFR 50.36(c)(2)(ii) criteria and are, therefore, not required to be in TS. The requirements have been incorporated into the Palisades ORM, which has been incorporated by reference into the FSAR.

Sufficient regulatory controls exist under 10 CFR 50.59 to ensure that any future changes to the requirements that constitute an unreviewed safety question will be subject to NRC review and approval prior to implementation. Therefore, the proposed deletion of these requirements is acceptable.

2.16 Shutdown Mode LCOs Existing LCO 3.7.3a requires, during shutdown, one safeguards bus to be operable and capable of being supplied by offsite power and by an operable DG. Existing LCO 3.7.3b contains the additional requirement that an additional safeguards bus be operable and capable of being supplied by offsite power when two trains of shutdown cooling are required by LCO 3.1.9, "Shutdown Cooling (SDC)."

The proposed LCO 3.7.2, "AC Sources - Shutdown," contains these same requirements of one operable offsite circuit and one operable DG when in cold shutdown or refueling shutdown with fuel in.the reactor, and during movement of irradiated fuel assemblies. The operable offsite circuit is capable of supplying both safeguards buses._ Therefore, a DG is required to be available to one safeguards bus and offsite power is required to be available to both, whether one or two trains of shutdown cooling are required.

Proposed LCO 3.7.10, "Distribution Systems - Shutdown," requires those buses necessary to support required equipment during shutdown to be operable. Therefore one safeguards bus must be operable when one train of shutdown cooling is required, and both buses when two trains are required.

The licensee considered these changes to be administrative because they propose reworded, but technically equivalent, requirements and merely move them within the TS.

On the basis of its review, the staff agrees with the licensee that the proposed changes are

. administrative and hence acceptable.

2.17 Reguired Actions for Inoperable AC Sources and Distribution Systems Existing Action Statements 3.7.3.A, 3.7.3.B, and 3.7.3.E require taking immediate action to suspend refueling operations (the Palisades TS equivalent to "core alterations" in the STS),

suspend movement of irradiated fuel, and to initiate action to restore the required electrical sources when less than the required electrical sources are operable.

Proposed LCO 3. 7.2 Required Actions A.2.1, A.2.2, A.2.4, B.1, 8.2, 8.3, and 8.4, and LCO 3. 7.10 Required Actions A.2.1, A.2.2, and A.2.4 require taking immediate action to suspend refueling operations, suspend movement of irradiated fuel, and initiate action to restore the required electrical equipment. The licensee considered this proposed change to be administrative because it proposes equivalent requirements and merely moves them within the TS.

On the basis of its review, the staff finds this proposed change to be administrative and hence acceptable.

2.18 Required Actions for Crane Operation and Coolant and Fuel Pool Inventory Control The licensee stated that existing Actions 3.7.3.C and 3.7.3.D, which require taking immediate action to suspend crane operation over irradiated fuel and suspend operations with a potential for draining the primary coolant system (PCS) or fuel pool, would be relocated to the ORM.

The licensee stated that these requirements do not meet the criteria of 10 CFR 50.36( c)(2)(ii) for inclusion in the TS. By letter dated June 27, 1997, the licensee stated that the requirements had been incorporated into the ORM.

These requirements are not needed to assure that any LCO will be met. The requirements have been incorporated into the Palisades ORM, which has been incorporated by reference into the FSAR. Sufficient regulatory controls exist under 10 CFR 50.59 to ensure that any future changes to the requirements that constitute an unreviewed safety question will be subject to NRC review and approval prior to implementation. Therefore, the proposed deletion of these requirements from the TS is acceptable.

2.19 Sequencer LCO Incorporated Into AC Sources LCO Existing LCO 3.17.2 currently requires the sequencers associated with each DG to be operable when the PCS is above 300 °F. Action 3.17.2.5 requires the associated DG to be immediately declared inoperable if a sequencer is inoperable.

. The licensee proposed that the sequencer requirements be incorporated into LCO 3. 7.1, "AC Sources - Operating," emulating the STS. Proposed LCO 3.7.1 requires the DGs to be operable when the PCS is above 210 °F, and includes the sequencer operability as a requirement for DG operability. Proposed Action 3.7.1.F requires that the associated DG be immediately declared inoperable if a sequencer is inoperable.

The proposed change is considered more restrictive than the existing TS requirements due to the change in applicability from above 300 °F to above 210 °F. Otherwise, the change proposes equivalent requirements and merely moves them within the TS. The staff finds this change to be an improvement of the existing requirement and hence acceptable. As part of this change, existing Action 3.17.2.6 would be renumbered to 3.17.2.5 in order to eliminate the gap

created in the specification numbering as a result of the incorporation of these requirements into LCO 3. 7.1. This is an administrative change that is acceptable to the staff.

2.20 Fuel Oil Inventory SR Existing SR 4.2, "Equipment and Sampling Tests," Table 4.2.2 item 8, requires verification of the quantity of fuel oil in the fuel oil storage tank daily. This requirement would be moved to SR 4. 7.3.1. The required amount of fuel oil, currently specified in existing LCO 3. 7.1 i as "a minimum of 16,000 gallons," would be increased to"?. 23,700 gallons." The licensee stated that the required amount of fuel has been increased to assure a 7-day supply considering the current accident load analysis.

The STS requires the fuel oil inventory in the storage tank to be verified each 31 days. The proposed Palisades fuel oil storage tank SR, which would require fuel oil inventory verification daily, is more restrictive because the fuel oil storage tank is the fuel oil supply for the diesel fire pumps, heating boilers, and rad waste evaporators, in addition to the DGs. The staff finds the proposed fuel oil storage tank inventory SR to be an improvement of the existing requirement that will ensure that a sufficient quantity of fuel oil is available to support DG operation.

Therefore, the proposed change is acceptable.

2.21 DG Standby Start SR The licensee proposed to revise the existing DG SR, TS 4.7.1.a, which has three parts:

Each diesel generator shall be manually started each month and demonstrated to be ready for loading within 10 seconds.

The signal initiated to start the diesel shall be varied from one test to another to verify that A and 8 starting circuits are operable.

The generator shall be synchronized from the control room, and loaded to 2400 +/- 100 kW.

The proposed revised wording, contained in SR 4. 7.1.2, restates the requirements of the first and third sentences, with the exceptions of the specified manual starting and synchronization from the control room. These details are omitted in the proposed wording because no practical alternatives exist. The proposed wording omits the requirements of the second sentence.

Since the DG is not assumed to be single-failure proof, the details of verifying that both of the starting circuits function would be left to the testing procedure.

The proposed wording of SR 4.7.1.2 combines the starting and timing tests of STS SRs 3.8.1.2 and 3.8.1. 7 because the Palisades DG design does not include a slow-starting option. The DG test requirements in proposed SR 4. 7.1.2 incorporate the existing requirement that the DG be ready for loading within 10 seconds with the modification that the DG achieves steady-state voltage?. 2280 and~ 2520 volts and frequency?. 59.5 and~ 61.2 Hz. DG start timing tests verify the time between the DG start signal and either the pickup of the voltage-sensing relays (for monthly tests, where automatic breaker closure does not occur) or the time between the

DG start signal and breaker closure (for 18-month loss of offsite power and safety injection signal (SIS) tests, where automatic breaker closure does occur). No installed instrumentation is available to determine precisely when voltage and frequency reach the band specified for

steady._state operation.

The proposed voltage* range is based on the DG rating of 2400 +/- 5% volts. This provides adequate margin for the switchgear and both the 2400- and 480-volt safeguards motors.

The proposed minimum frequency is based on the accident analyses rather than on electrical limitations. The accident analyses made no specific allowance for operation of the safeguard pumps at other than design speed. T_hese analyses do, however. contain sufficient margin to assure adequate flow at a frequency of 59.5 Hz. The proposed maximum frequency is based on the STS; the proposed minimum frequency is more conservative than the STS value and conforms to the guidance of Regulatory Guide (RG) 1.9, "Selection, Design, and Qualification of Diesel-Generator Units Used as Standby (Onsite) Electric Power Systems at Nuclear Power Plants."

The licensee stated that because the peak predicted accident load is different for each DG, the proposed peak load testing requirement in SR 4.7.1.3 includes not only automatically connected loads, but operator-connected loads that might be necessary under some circumstances. When potential operator-connected loads are included, the predicted accident load profile exceeds the continuous rating of the DG (but remains within the overload ratings) for a short time early in the event. The requirement that the DG be "loaded above the peak accident loading" for 15 minutes demonstrates the ability of the engine to supply this possible peak foad, yet the DG is not routinely loaded over its continuous rating for a lengthy period:

The 2300- to 2500-kW load range proposed for the balance of the monthly test is unchanged from the existing requirements.

The Palisades DGs are rated at 2750 kW for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and 2500 kW for continuous loading.

Therefore, the proposed testing is within the design rating of the DG and is not an "overload."

No change was proposed for the testing intervals.

On the basis of its review, the staff finds that the proposed SRs are adequate to assure that the necessary quality of the DG will be maintained. Therefore, the proposed SRs are acceptable.

2.22 AC Power Sources Response to SIS Coincident with Loss of Offsite Power SR Existing SR 4. 7.1 b requires testing the overall operation of the emergency power system in responding to an SIS coincident with a loss of offsite power. This same test is required by proposed SR 4. 7.1.13. The proposed wording is taken from the STS and includes requirements for verification of steady-state voltage and frequency that are not included in the existing TS requirement.

The proposed change is considered more restrictive than the existing TS requirement due to the additional verifications that are proposed to be performed. Otherwise, the change proposes equivalent requirements and merely moves them within the TS. The staff finds this change to be an improvement on the existing requirement and hence acceptable.

2.23 DG Inspection SR Relocated Existing SR 4. 7.1 c requires an inspection of each DG during plant shutdown each refueling cycle. By letter dated June 27, 1997, the licensee stated that the requirement had been incorporated into the ORM.

This requirement is not needed to assure that any LCO will be met. The licensee has proposed revisions to existing SRs and additional SRs in this request that are sufficient to ensure continued DG operability. This requirement has been incorporated into the ORM. Sufficient regulatory controls exist under 10 CFR 50.59 to ensure that any future changes to the requirement that constitute an unreviewed safety question will be subject to NRC review and approval prior to implementation. Therefore, the proposed deletion of this requirement is acceptable.

2.24 DG Load Verification SR Relocated Existing TS SR 4. 7.1 d requires verification that DG continuous loads have not been increased beyond the DG continuous rating. The licensee proposed to delete this requirement from the proposed TS. This requirement was incorporated into the Palisades FSAR, Section 8.4.1.3, regarding the DG design analyses, in the FSAR update submitted on June 27, 1997. The FSAR states:

When any plant modification affects the diesel generator loading, the revised loading will be verified to not exceed either the engine or generator ratings.

The staff finds that the DG load profile is a design requirement that is more appropriately reflected in the FSAR. The licensee has proposed revisions to existing SRs and additional SRs in this request that are sufficient to ensure continued DG operability. This requirement has been incorporated into the Palisades FSAR. Sufficient regulatory controls exist under 10 CFR 50.59 to ensure that any future changes to the requirement that constitute an unreviewed safety question will be subject to NRC review and approval prior to implementation. Therefore, the proposed deletion of this requirement is acceptable.

2.25 Fuel Transfer System SR Existing SR 4.7.1e requires that the fuel oil pump operability be verified each month. Proposed SR 4.7.1.6 contains this verification requirement, but at a 92-day frequency. The proposed frequency is consistent with Section XI, lnservice Testing Requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code and is consistent

with the STS.

On the basis of its review, the staff finds that the proposed SR is adequate to assure that the DG LCO will be met and is consistent with industry operating experience as reflected in the STS. Therefore, the proposed SR is acceptable.

2.26 Station Battery SRs Existing SR 4. 7.2a requires monthly measurement of each battery cell voltage and of pilot cell specific gravity and temperature. Proposed SR 4.7.6.1 requires verification that pilot cell electrolyte level, float voltage, and specific gravity meet the requirements in Table 3.7.6-1; proposed SR 4.7.6.2 requires measurement of pilot cell temperatures. No change has been proposed for the frequency of these measurements from the existing SR frequency of 31 days.

Existing SR 4.7.2b requires measuring the specific gravity, electrolyte level, and amount of water added for each cell, and the temperature of every fifth cell every 3 months; proposed SR 4.7.6.3 requires verification every 92 days that electrolyte level, float voltage, and specific

~

gravity of each cell meet the requirements in Table 3.7.6-1. Proposed SR 4.7.6.2 requires verification every 31 days that the temperature of the pilot cells is~ 70 °F.

The proposed SRs contain all of the requirements of the existing SRs with the exception of measuring and recording the amount of water added to the battery. That requirement is

considered to be a maintenance practice and does not appear in the STS. It has been proposed to be deleted by the licensee. The licensee stated that the proposed values in Table 3.7.6-1 are the same as, or more conservative than, the recommendations of STS Table 3.8.6-1. The proposed values were revised based on the guidance of the battery manufacturer that specific gravity limits be derived from the cell baseline values. The!: 1.205 Category A limit proposed will assure that no cell is more than 0.006 below the average baseline specific gravity for the battery. The licensee will thus not have to track separate baseline values for each cell. Similarly, the~ 1.200 Category B limit proposed will assure that no cell is more than 0.011 below the average baseline value. An additional limit is proposed to assure that the average specific gravity is no more than 0.006 below the average baseline value. The Category C limit agrees with the recommendation of the STS.

Footnote (c) has been revised to reflect the recommendations of the manufacturer and to allow battery float charging current as an acceptable measure of the battery state of charge in lieu of specific gravity limits.

The proposed changes are considered less restrictive because they would delete the requirement to* measure and record the amount of water added to the battery.* The requirement regarding addition of water to the battery is not needed to assure that the necessary quality of the battery is maintained or that the battery LCO will be met. Therefore, deletion of this requirement is acceptable. Although the 31-day frequency of SR 4.7.6.1 differs from the 7-day frequency of the STS, the staff finds that the licensee has proposed substantial improvements to the existing requirements by including Category A, B, and C limits on multiple battery parameters (electrolyte level, float voltage, and specific gravity). The proposed SR will assure that the battery LCO will be met, and is acceptable to the staff.

Existing SRs 4.7.2c and 4.7.2d are equivalent to proposed SRs 4.7.4.7 and 4.7.4.8. Proposed *

SR 4.7.4.7, "Battery service test," revises existing SR 4.7.2.c to read:

Verify battery capacity is adequate to supply, and maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a

battery service test; each 18 months. (The modified performance discharge test of surveillance 4.7.4.8 may be performed in lieu of this test.)

Proposed SR 4.7.4.8, "Battery performance test," revises existing SR 4.7.2.d to read:

Verify battery capacity is ~ 80% of the manufacturer's rating when subjected to a performance discharge test or a modified performance discharge test; each 60 months. This test shall be performed each 12 months when battery shows degradation or has reached 85% of the expected life with capacity <:: 100% of manufacturer's rating, or each 24 months when batt~ry has reached 85% of the expected life with capacity~ 100% of manufacturer's rating.

Additionally, the licensee included a footnote to SRs 4.7.4.7 and 4.7.4.8 that states:

These tests must be performed in COLD SHUTDOWN or REFUELING SHUTDOWN.

This is equivalent to the existing SRs, which include a requirement that the surveillances be performed during shutdown. The licensee stated that the proposed wording is taken from the STS and is based upon the recommendations of IEEE Standard 450 - 1995.

This proposed change is considered administrative because it proposes equivalent requirements and merely moves them within the TS. On the basis of its review, the staff finds the proposed changes to be acceptable.

2.27 Emergency Lighting SR Relocated SR 4.7.3 contains requirements for testing the emergency lighting system. There is no corresponding LCO. The licensee stated that these requirements would be relocated to the ORM. By letter dated June 27, 1997, the licensee stated that the requirements had been incorporated into the ORM.

This requirement is not needed to assure that any LCO will be met. This requirement has been incorporated into the ORM. Sufficient regulatory controls exist under 10 CFR 50.59 to ensure that any future changes to the requirement that constitute an unreviewed safety question will be subject to.NRG review and approval prior to implementation. Therefore, the proposed deletion of this requirement is acceptable.

2.28 Seguencer SRs Section 4 of Surveillance Table 4.17.2 requires a channel functional test of each DBA

[design-basis accident] sequencer each 92 days, and a channel functional test of each Normal Shutdown Sequencer and a channel calibration of each sequencer each 18 months.

The licensee stated that the channel functional test requirement for the DBA sequencer is redundant to the 92-day test required by footnote (a) of that table and it has been omitted from the proposed TS (footnote (a) remains unchanged as it is applicable to other TS Table 4.17.2

items). Proposed SRs 4.7.1.9 and 4.7.1.13 (discussed in Section 2.29) include a test requirement to verify that auto-connected loads are energized through the automatic load sequencers. This* accomplishes the channel functional tests of the Normal Shutdown Sequencer and the DBA Sequencer as currently required by the existing Table 4.17.2 requirement. The proposed SRs are equivalent to the existing SRs but emulate the STS wording and location for these requirements.

The proposed change merely moves requirements within the TS. Therefore, the staff finds this change to be acceptable.

2.29 New LCOs, Conditions. and Actions to Emulate the STS The licensee proposed a number of new requirements that. are more restrictive than those in the existing TS. Examples include new LCOs, more restrictive action requirements for inoperable equipment, and more restrictive SRs. Table 1 lists these new requirements, providing the proposed TS reference and a summary description of the more restrictive change.

These changes are additional restrictions on plant operation that enhance safety and are acceptable to the staff. Additional discussion of the staff's review of several of these new requirements is provided in the following paragraphs.

With respect to proposed SR 4.7.1.8, the staff raised concerns regarding the 4000-volt upper limit for the voltage transient during the test (the STS specifies 2880 volts) and operation of the DG at a power factor of ~ 0.9 instead of the calculated accident loading power factor.

The licensee responded that the 4000-volt limit was proposed because the full load rejection test must be performed with the DG parallel to the grid. Additionally, to achieve a specified power factor, the voltage regulator must be adjusted as the DG is loaded. Since Palisades has no feature to automatically return the voltage regulator control from parallel to isochronous, the voltage transient may (depending ori grid voltage and power factor at the time of the test) be higher than on a DG with such a feature. The licensee stated that the proposed 4000-volt transient limit is *acceptable because the switchgear is rated at 4160 volts, the connecting cabling is rated at 5000 volts, the DG is rated at 4160 volts when star-connected (and 2400 volts delta), and the generator was wound with 5000-volt insulation. Additionally, the licensee contacted the manufacturers of the DG, governor, and voltage regulator and confirmed that a short.duration spike of 4000 volts should not affect the function of DG instrumentation and associated relays. The licensee stated that the digital watt meters are the weakest link in terms of voltage rating for the DG instrumentation and controls. The digital watt meters are protected to 200% or 240 volts ac (4000 volts at the generator output breaker translate to 200 volts ac at the watt meters). This information resolves the staff's concern regarding the proposed voltage limit.

With regard to testing the DG at the accident loading power factor, the licensee stated that the proposed limiting power factor of 0.9 does not bound the calculated accident loading power factor. The minimum calculated power factor for each DG approaches 0.85. The proposed power fi;ictor of 0.9 for this SR is in conformance with the power factor of~ 0.9 recommended by RG 1.9, Rev. 3, during this test. In addition, a reduced power factor limit would be overly restrictive during testing; the DG rating limits the power factor to 0.8, and a testing requirement

of~ 0.85, adjusted for instrument error bands, would restrict testing to a band of about 0.82 to 0.83. Based on the above, the staff concludes that considering the instrument error bands at Palisades, testing of the DG at 0.9 power factor will likely be close to the accident loading power factor. Moreover, the addition of this SR to the Palisades TS is an improvement over the current TS, which do not include a similar SR.

With respect to SR 4. 7.1.10, the licensee stated that the Palisades DGs have a continuous.

rating of 2500 kW and a 2-hour rating of 2750 kW. If the proposed SR specified 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months at a.

load above the continuous rating, a test duration of more than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months would exceed the DG rating and a test duration of less than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months would not satisfy the SR. In selecting 100 minutes to demonstrate that the DG is not degrading, the licensee has met the intent of the STS SR requirement.

The staff finds the addition of this SR to the Palisades TS to be an improvement over the current TS, which do not include a similar SR. On this basis the staff finds testing of the DG for 100 minutes in lieu of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to be acceptable. The staff's evaluation regarding testing the DG during the 24-hour test at a power factor of 0.9 in lieu of the accident loading power factor is discussed above in relation to SR 4.7.1.8.

Additionally, the licensee has proposed to allow the performance of SRs 4.7.1.7, 4.7.1.8, and 4.7.1.10 at power. The STS normally requires that these SRs be performed during shutdown.

The staff was concerned that performance of these SRs during power operation could result in an undue increase in plant risk.

In response to the staff's concerns the licensee stated that SRs 4. 7. t. 7 and 4. 7.1.8 constitute new requirements for Palisades. The purpose of these SRs is to verify proper functioning of the DG governor and voltage regulator. If either of these components were repaired or replaced during online DG maintenance, the SRs would have to be performed to verify DG operability. If the subject restriction (performance of these tests at shutdown periods) were added to the proposed TS, either replacement or major repair of one of these DG components would require a plant shutdown to perform the required post-maintenance testing. Plant operating history includes occasions when the DG has tripped while paralleled to its 2400-volt bus without

causing significant disturbance to the plant distribution system. On September 17, 1991, during testing, an intermittent voltage regulator response caused the DG to trip while loaded to 2400 kW. The power factor at the time of the breaker trip (on overcurrent) was less than 0.8. There was no disturbance to plant loads.

With regard to SR 4. 7.1.10, the licensee stated that at Palisades, a DG must be considered to be inoperable when it is paralleled to the grid because there is no feature to restore the DG controls to the proper standby conditions. The existing TS allow a DG to be made. inoperable for up to 7 days to perform maintenance. The licensee stated that paralleling the DG with the grid for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months has far less impact than physically disabling a DG for maintenance for as much as a week. The new SR was therefore proposed without the restriction of limiting the performance of this test to shutdown periods.

In response to the staff's concern regarding the effect of a plant trip on the Class 1 E electrical distribution system while the DG is operating in parallel with offsite power, the licensee stated that during normal plant operation the safeguards transformer provides power to both Class 1 E emergency buses. The safeguards transformer is directly connected to the grid via the Palisades switchyard "F" Bus. The safeguards transformer has an automatic tap changing feature which will automatically adjust output voltage. Power to the emergency buses during plant trip should not be affected as no fast transfer of emergency bus supply power occurs; the safeguards transformer maintains supply to the emergency buses.

When the plant trips while the DG is in the parallel mode of operation, circuit relaying will actuate to open the DG output breaker causing a full load rejection. Relays then provide a 1.5-second delay before allowing the DG output breaker to reclose for load sequencing if offsite power is lost. If offsite power is not lost, the DG continues to run in stand-by with its output breaker open. The licensee analyzed the effect of failure of these circuit relays. Case 1 deals with the operation of the DG while paralleled to the grid with the plant on line, and the main generator trips with the DG output breaker failing to open. In this case, loss of the main turbine generator could cause reactive load changes on the grid which could propagate through the safeguard transformer (provides power to both Class 1 E buses) to the paralleled DG. The licensee stated that the impact on the DG voltage regulator is minimal. The current voltage control band on the DG is approximately 2200 to 2700 volts ac while in parallel. These values translate to grid voltages of 316,000 to 388,000 volts, which are far outside the range of grid voltages experienced at Palisades. Additionally, current limiting resistors are an integral part of the volta*ge regulation protection. The primary concern is the DG windings due to the voltage offset between the DG reference and grid voltages. The offset could result in DG operation outside of the nameplate specified power factor ratings. However, overcurrent relays on the DG output breakers are set for DG overload protection.

Also, an additional relay is set at 100% of DG rated output for annunciation. This annunciation is provided to alert operators to an overload condition. Additionally, all operators are trained to recognize how reactive power and frequency changes on the grid, caused by either Palisades main turbine generator or offsite influences, affect a paralleled DG.

Case 2 deals with the operation of the DG while paralleled to the grid with the plant offline. This condition may exist with either the safeguards transformer, station transformer, or start-up transformer as the power source for the Class 1 E buses. The station and start-up transformers are not tap changing and, therefore, changes in the grid reactive loading may have greater impact on the DG. In either case, voltage regulator protection and breaker protection are the same as discussed above.

The licensee believes that*a loss of load scenario with the DG paralleled to the grid has some likelihood of occurring. Therefore, by letter dated November 21, 1997, the licensee committed to complete an evaluation of this condition by April 30, 1998, to determine if existing procedures provide the operators with sufficient guidance for actions to be taken should such an event occur. The licensee indicated that procedures would be revised if determined necessary as a result of this evaluation. By letter dated April 10, 1998, the licensee stated that these actions had been completed.

On the basis of its review, the staff finds the above concern resolved and concludes that performance of these SRs (4.7.1.7, 4.7.1.8, and 4.7.1.10) at power would not cause any undue

transient on the Class 1 E distribution system. Moreover, the addition of these SRs in the Palisades TS is an improvement over the current TS, which do not include similar SRs.

Alternative Actions to TS 3.0.3 The licensee also proposed several conditions that provide alternative actions to the shutdown currently required under the associated conditions of LCO 3.0.3. These conditions and the associated actions (TS 3. 7.1, Required Actions C.2, D.1, D.2, and E.1) are applicable when two required ac sources are discovered to be inoperable. The proposed actions provide limited AOTs to restore inoperable offsite circuits or DGs before requiring commencement of a plant shutdown. The licensee stated that these alternative actions are in agreement with the STS and with the recommendations of RG 1.93, "Availability of Electric Power Sources." The licensee stated that it was considered to be more desirable to allow limited continued operation to attempt to restore the inoperable equipment than to require an immediate plant shutdown with the limited ac sources available in these configurations.

Upon discovery of the failure to meet an LCO, the STS specify times for completing required actions of the associated TS conditions. Required actions of the associated conditions are used to establish remedial measures that must be taken within specified completion times (AOTs). These times define limits during which operation in a degraded condition is permitted.

The licensee's proposal to adopt completion times from the STS is acceptable because these completion times take into account the operability of the redundant systems of TS required features, the capacity and capability of the remaining features, a reasonable time for repairs or replacement of required features, and the. low probability of a design-basis accident occurring during the repair period.

2.30 Bases for Proposed Electrical Technical Specifications The licensee proposed to delete the existing Bases sections and replace them with sections that provide more detailed bases for each LCO, action, and surveillance requirement. During its review, the staff identified a number of typographical errors in the proposed Bases. These were discussed with the licensee and corrected by the staff.

On the basis of its review, the staff finds this change to be acceptable.

3.0

SUMMARY

On the basis of its review, the staff finds the licensee's request to be acceptable. Overall, the staff finds the amended TS to be an improvement to the existing TS.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Michigan State official was notified of the proposed issuance of the amendment. The Michigan State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The staff has determined that the amendment. involves no significant increase in the amounts,* and no significant change in the types, of any eijluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding (62 FR 17229). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors:

Date: April 29, 1998

Attachment:

Table 1 A. Pal D. Shum K. Parczewski R. Schaaf Table 1 - New, More Restrictive Requirements Proposed TS.

Summary of Change LCO 3.7.1 Requirement added to perform offsite circuit verification for the Required Action A.1 operable offsite circuit when the redundant offsite circuit is inoperable.

LCO 3.7.1 Requirement added to declare a required feature supported by an Required Action C.1 inoperable offsite circuit to be inoperable when its redundant required feature is discovered to be inoperable concurrently with two inoperable offsite circuits.

LCO 3.7.1 Requirement added to declare DG 1-2 inoperable within 15 hours1.736111e-4 days 0.00417 hours 2.480159e-5 weeks 5.7075e-6 months Required Action G.1 from the time that fuel transfer pump P-18A is discovered to be inoperable.

Either fuel oil transfer pump is capable of supplying fuel oil to either DG via a common header. However, each fuel oil transfer pump is not capable of being powered from either DG. DG 1-1 can power either fuel oil transfer pump, but DG 1-2 can only power P-18A.

P-18A is normally powered by DG 1-1 through motor control center (MCC)-8, which is non-Class 1 E. In an emergency, P-18A can be powered by DG 1-2 through cross connected Class 1 E load centers (LC-11 and LC-12). P-188 is powered by DG 1-1 through Class 1E MCC-1 and cannot be powered by DG 1-2.

The day tank for each DG is required to store a minimum of 2,500 gallons of fuel oil, which is sufficient for 15 hours1.736111e-4 days 0.00417 hours 2.480159e-5 weeks 5.7075e-6 months of associated DG operation at full load. Therefore, with fuel transfer pump P-18A inoperable, DG 1-2 will be able to operate for 15 hours1.736111e-4 days 0.00417 hours 2.480159e-5 weeks 5.7075e-6 months . The licensee initially proposed a 24-hour AOT for P-18A. The licensee stated that the proposed AOT was not based on the DG run time with the available fuel oil stored in the day tank, it was based on a judgement of the relative severity of both DGs being inoperable or both offsite sources being inoperable and was intended to allow a reasonable time for repair of P-18A prior to declaring DG 1-2 to be inoperable. However, the licensee did not discuss how the relative severity of both DGs being inoperable or both offsite sources being inoperable was determined.

(continued on next page)

ATTACHMENT

Proposed TS Summary of Change LCO 3.7.1 In its RAI dated November 4, 1996, the staff commented that the Required Action G.1 fuel oil stored in the day tank is only sufficient to support DG 1-2 (continued) operation for 15 hours1.736111e-4 days 0.00417 hours 2.480159e-5 weeks 5.7075e-6 months . Therefore, the AOT for P-18A should be less than 15 hours1.736111e-4 days 0.00417 hours 2.480159e-5 weeks 5.7075e-6 months . In its response dated November 26, 1996, the licensee stated that a reduction in the proposed P-18A AOT from 24 to 15 hours1.736111e-4 days 0.00417 hours 2.480159e-5 weeks 5.7075e-6 months would be acceptable. In its supplemental submittal dated June 27, 1997, the licensee revised the proposed TS to reflect the reduction in the proposed P-18A AOT from 24 to 15 hours1.736111e-4 days 0.00417 hours 2.480159e-5 weeks 5.7075e-6 months .

LCO 3.7.1 Requirement added to restore fuel transfer pump P-188 to Required Action H.1 operable status within 7 days.

As noted in the discussion regarding LCO 3.7.1 Action G.1, above,

. either DG can still provide power to the remaining fuel transfer pump, P-18A, such that neither DG is directly affected. Therefore, the loss of P-188 is less severe than the loss of one DG. However, continued operation with only P-18A must be limited since an additional single active failure could disable the onsite power system.

LCO 3.7.1 Requirement added to restore one fuel transfer pump to operable Required Action 1.1 status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months when both fuel transfer pumps are discovered to be inoperable.

TS 3.7.1 Requirement added to enter TS 3.0.3 immediately when three ac Required Action K.1 sources are discovered to be inoperable.

LCO 3.7.2 Requirement added to declare a required feature of an inoperable Required Action A.1 offsite circuit to be inoperable.

LCO 3.7.2 Requirement added to suspend operations involving positive Required Action A.2.3 reactivity addition when a required offsite circuit is discovered to be inoperable.

LCO 3.7.2 Requirement added to suspend operations involving positive Required Action 8.3 reactivity addition when a required DG is discovered to be inoperable.

LCO 3.7.3 LCO added to require stored o*G fuel oil and lube oil to be within specified limits when any DG is required to be operable.

ATTACHMENT Proposed TS Summary of Change LCO 3.7.3 Requirement added to restore stored fuel oil inventory when it is Required Action A.1 discovered to be outside the specified limits.

Certain circumstances (e.g., feed and bleed operations that may be necessary to correct particulate levels or other oil quality degradations) may cause DG fuel oil level(s) to drop below the 7-day limit. The restriction of this proposed TS maintains at least a 6-day fuel oil supply for one DG and allows sufficient.time to obtain the requisite replacement fuel oil and to perform analyses required prior to addition of the fuel oil to the tank(s).

A period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is consider to be sufficient to complete restoration of the required level prior to declaring the DG(s) inoperable. This period is acceptable based on the remaining fuel oil inventory (at least 6 days), the fact that procedures are in place to obtain replacement, and the low probability of an event occurring during this brief period.

LCO 3.7.3 Requirement added to restore stored lube oil inventory when it is Required Action 8.1 discovered to be outside the specified limits.

The restriction described in this proposed TS maintains at least a 6-day lube oil supply for DG operation and allows sufficient time to obtain the requisite replacement lube oil.

A period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is considered to be sufficient to complete restoration of the required lube oil quantity prior to declaring the DG(s) inoperable. This period is acceptable based on the remaining lube oil inventory (at least 6 days), the fact that procedures are in place to obtain replacement, and the low probability of an event occurring during this brief period.

LCO 3.7.3 Requirement added to declare both DGs inoperable when specified Required Action C.1 fuel oil properties (viscosity, or water and sediment) are discovered to be outside their specified limits.

LCO 3.7.3 Requirement added to restore stored fuel oil properties (other than Required Action D.1 viscosity, and water and sediment) to within limits when they are discovered to be outside the specified limits.

LCO 3.7.3 Requirement added to declare both DGs inoperable when any Required Action E.1 action required by 3.7.3.A through 3.7.3.D is not met and the associated completion time has expired, or if LCO 3.7.3 is not met for other reasons.

LCO 3.7.5 LCO added to required operable de sources needed to support de distribution systems required by LCO 3.7.10 when the plant is in cold shutdown or refueling shutdown with fuel in the reactor, and during movement of irradiated fuel assemblies.

Proposed TS Summary of Change LCO 3.7.5 Requirement added to declare affected features inoperable when a Required Action A.1 requited de source is discovered to be inoperable.

LCO 3.7.5 Requirement added to suspend refueling operations when a Required Action A.2.1

required de source is discovered to be inoperable.

LCO 3.7.5 Requirement added to suspend movement of irradiated fuel Required Action A.2.2 assemblies when a required de source is discovered to be inoperable.

LCO 3.7.5 Requirement added to suspend operations involving positive Required Action A.2.3 reactivity addition when a required de source is discovered to be inoperable.

LCO 3.7.5 Requirement added to restore an inoperable de source to service Required Action A.2.4 when it is discovered to be inoperable.

LCO 3.7.6 LCO added to require battery cell parameters to be within the limits specified in proposed Table 3.7.6-1 and for average electrolyte temperature of representative cells to be ?.70 °F when associated de power sources are required to be operable.

LCO 3.7.6 Requirement added to verify battery pilot cell parameters to be Required Action A.1 within Category C limits when one or more batteries are discovered to have cell parameters not within Category A or B limits.

LCO 3.7.6 Requirement added to periodically verify battery cell parameters to Required Action A.2 be within Category C limits when one or more batteries are discovered to have cell parameters not within Category A or B limits.

LCO 3.7.6 Requirement added to restore battery cell parameters to Category Required Action A.3 A and B limits when one or more batteries are discovered to have cell parameters not within Category A or B limits.

LCO 3.7.6 Requirement added to declare an affected battery inoperable Required Action 8.1 when: any Action required by.3.7.6.A has not been met and the allowed completion time has expired; or when one or more batteries' average electrolyte temperature is discovered to be

<70 °F; or when one or more battery cell parameters are discovered to be outside Category C limits.

LCO 3.7.6 Table added to specify acceptable battery cell parameter Category Table 3.7.6-1 A, B, and C limits.

LCO 3.7.7 LCO added for operable inverters when the plant is above cold shutdown.

LCO 3.7.7 Requirement added to complete the applicable actions of LCO Required Action A.1 3.7.9 if any preferred ac bus is de-energized when an inverter is discovered to be inoperable.

Proposed TS Summary of Change LCO 3.7.7 Requirement added to restore an inoperable inverter to service Required Action A.2 when it is discovered to be inoperable.

LCO 3.7.8 LCO added for operable inverters needed to support the preferred ac distribution systems required by LCO 3. 7.10 when the plant is in cold shutdown or refueling shutdown with fuel in the reactor, and during movement of irradiated fuel assemblies.

LCO 3.7.8 Requirement added to declare affected features inoperable when a Required Action A.1 required inverter is discovered to be inoperable.

LCO 3.7.8 Requirement added to suspend refueling operations when a Required Action A.2.1 required inverter is discovered to be inoperable.

LCO 3.7.8 Requirement added to suspend movement of irradiated fuel Required Action A.2.2 assemblies when a required inverter is discovered to be inoperable.

LCO 3.7.8 Requirement added to suspend operations involving positive Required Action A.2.3 reactivity addition when a required inverter is discovered to be inoperable.

LCO 3.7.8 Requirement added to restore an inoperable inverter to service Required Action A.2.4 when it is discovered to be inoperable.

LCO 3.7.10 Requirement added to declare affected features inoperable when a Required Action A.1 required distribution system is discovered to be inoperable.

LCO 3.7.10 Requirement added to suspend operations involving positive Required Action A.2.3 reactivity addition when a required electrical power distribution subsystem is discovered to be inoperable.

LCO 3.7.10 Requirement added to declare affected shutdown cooling trains to Required Action A.2.5 be inoperable when a required electrical power distribution subsystem is discovered to be inoperable.

SR 4.7.1.1 Requirement added to periodically verify offsite circuit alignment and voltage.

The requirement proposed by the licensee is slightly different from the requirement of the STS (SR 3.8.1.1 }, which requires verification of power availability in lieu of voltage. The licensee stated that installed.instrumentation is available for voltage, but not for available power. Since the licensee will verify voltage for each offsite source, the staff considers this to be adequate to demonstrate* the availability of offsite power sources.

Proposed TS SR 4.7.1.4 SR 4.7.1.5 SR'4.7.1.7 SR 4.7.1.8 SR 4.7.1.10 SR4.7.1.11 Summary of Change Requirement added to periodically verify DG starting air tank pressure.

The Standard Review Plan, NUREG-0800, provides guidance that the air starting system should be capable of cranking a cold diesel engine five times without recharging the air receiver(s). Each cranking cycle duration should be approximately 3 seconds. STS LCO Section 3.8.3 allows a 48-hour AOT when starting air pressure is below the required five start capability, but sufficient for at least one start. The licensee stated that the Palisades design does not specify the capability for five attempted DG starts.

However, the design information states that with starting air tank pressure ~200 psig sufficient air is available for approximately 40 seconds of cranking time. With below normal pressure, no specific number of starts can be assured and the DG must be assumed to inoperable.

Requirement added to periodically verify DG day tank fuel quantity.

Requirement added to periodically verify that each DG performs acceptably following the largest projected post-accident load rejection.

The licensee stated that the proposed time, voltage, and frequency limits are derived from the recommendations of RG 1.9, Rev. 3.

RG 1.9 recommends that the increase in diesel speed during the transient should not exceed 75% of the difference between synchronous speed and the overspeed trip setpoint, or 15% above synchronous speed, whichever is lower. The Palisades DGs have a synchronous speed of 900 rpm and an overspeed trip setting range of 1060 to 1105 rpm. Therefore, the maximum acceptable frequency for this SR is 68 Hz. The licensee stated that the maximum acceptable steady-state frequency is slightly higher than the +2% (61.2 Hz) recommended by RG 1.9 because the test must be performed with the DG controls in the parallel mode. The increased frequency allowance of 0.3 Hz is based on the expected speed differential associated with performance of the test in the parallel mode.

Requirement added to periodically verify that each DG does not trip following a full load rejection.

Requirement added to periodically verify that each DG. performs acceptably during a 24-hour load test.

Requirement added to periodically verify that each DG can be synchronized with the offsite power circuit and the load can be transferred acceptably to the offsite circuit.

Proposed TS Summary of Change SR4.7.1.12 Requirement added to periodically verify the timing of DG load sequencing.

The licensee stated that this SR is worded differently than the STS SR to verify the timing of each load, rather than the intervening interval. The Palisades sequencers are solid state devices which are verified to be within 0.3 second of the programmed time. Plant testing procedures are written to verify that the timing meets the accident analyses, and DG load studies allow for the maximum allowable sequence error.

SR 4.7.2.1 Requirement added to perform necessary SRs associated with LCO 4.7.1 to verify each required ac power source is operable.

The licensee stated that the intent of the STS SR requirement is not changed; however, the proposed SR is reworded for consistency. Palisades does not differentiate between an SR that has to be met and an SR that has to be performed. The proposed SRs can be performed only with the required equipment available.

For example, since paralleling a DG with the grid for load testing would make that DG inoperable, no DG load testing requirements have been proposed during shutdown periods. If such a surveillance were required, its performance would make the only operable DG inoperable, thereby deviating from the requirements of the proposed LCO.

SR 4.7.3.2 Requirement added to periodically verify the lube oil quantity.

SR 4.7.3.3 Requirement added to periodically verify the fuel oil properties, specified in the Fuel Oil Testing Program, TS 6. 5.11.

SR 4.7.3.4 Requirement added to periodically check for and remove excess accumulated water from the.fuel oil storage tank.

SR 4.7.4.1 Requirement added to periodically verify the battery terminal voltage.

The licensee stated that the proposed value of 125 V for minimum battery terminal voltage was selected based on the de system design. An initial terminal voltage of 125 V is sufficient for the battery to successfully complete the battery testing and battery performance testing required by proposed SRs 4.7.4.7 and 4.7.4.8, respectively.

Proposed TS Summary of Change SR 4.7.4.2 Requirement added to periodically verify that there is no visible corrosion at battery terminals and connectors, or to verify connection resistances.

The licensee stated that the specified limits are in accordance with the manufacturer's recommendations. The 50 µohm value is based on the minimum battery design voltage. Battery sizing calculations show the first-minute load on the ED-02 battery as the load that determines battery size; hence, battery voltage will be at its lowest value while the battery supplies this current. Calculations also show that at a minimum temperature and end-of-life (80%)

battery performance, battery voltage during this first-minute load will be about 1.815 volts per cell, assuming nominal connection resistance. But if all the connections were at the ceiling value of 50

µohms, the additional voltage drop would result in a battery voltage of about 1. 79 volts per cell, which is still above the minimum design voltage of 1. 75 volts per cell.

The 360 µohm value is based on the nominal cumulative resistance of the components that make up the connections: resistance of the connecting cable, the battery-post-to-cable-lug connection, the cable lug itself, and the lug-to-cable connection.

SR 4.7.4.3 Requirement added to periodically inspect batteries for visual indications of physical damage or abnormal degradation.

In specifying "inspect" rather than "verify no damage," the licensee avoids having to declare the battery inoperable for observed damage that does not affect operability.

SR 4.7.4.4 Requirement added to periodically remove visible terminal corrosion and verify cell to cell and terminal connections are coated with anti-corrosion material.

SR 4.7.4.5 Requirement added to periodically verify each battery connection resistance.

See discussion for SR 4.7.4.2.

SR 4.7.4.6 Requirement added to periodically verify battery charger performance.

The licensee stated that the requirement of this SR is unchanged from that of corresponding STS SR except that the test will be performed during plant operation at Palisades, because the plant is equipped with two chargers for each battery and only one charger for each battery is required to be operable. The test may be performed on the standby charger while the other charger is in service. The new SR omits the restriction of limiting the performance of this test to shutdown periods.

Proposed TS Summary of Change SR4.7.5 Requirement added to perform necessary SRs associated with LCO 3.7.4 to verify each de source is operable.

The licensee stated that the intent of the STS SR requirement was not changed; however, the proposed SR was reworded for consistency.

SR 4.7.7.1 Requirement added to periodically verify inverter performance.

SR 4.7.8.1 Requirement added to periodically verify inverter performance.

SR 4.7.9.1 Requirement added to periodically verify breaker alignment and voltage to required electrical power distribution subsystems.

SR4.7.10.1 Requirement added to periodically verify breaker alignment and voltage to required electrical power distribution subsystems.

6.5.11 Administrative Controls requirement added to establish and maintain a diesel fuel oil testing program.

The staff noted that the proposed program generally followed the format of the STS, except that the proposed specification does not require measurement of total particulate concentration. The licensee stated that at Palisades the rate of consumption of fuel oil is very high and its residence time in the fuel tank is conseque,ntly

.too short to cause significant degradation. Based on the licensee's justification, the staff agreed that trending of particulates is not necessary at Palisades.

ML18065B241

Contents

Text

1.0 INTRODUCTION

SUMMARY

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

Attachment:

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ML18065B241

Text

1.0 INTRODUCTION

SUMMARY

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

Attachment:

Navigation menu

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