ML18066A288
| ML18066A288 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/21/1998 |
| From: | Robert Schaaf NRC (Affiliation Not Assigned) |
| To: | Haskell N CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| TAC-MA0805, TAC-MA805, NUDOCS 9808280197 | |
| Download: ML18066A288 (7) | |
Text
'...
I '
Mr. Nathan L. Haskell Director, Licensing Palisades Plant 27780 Blue Star Memorial Highway Covert, MI 49043 August 21, 1998
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING THE TECHNICAL SPECIFICATIONS CHANGE REQUEST TO CONVERT TO THE IMPROVED TECHNICAL SPECIFICATIONS FOR THE PALISADES PLANT (TAC NO.
MA0805)
Dear Mr. Haskell:
On January 26, 1998, Consumers Energy submitted its request to convert the Palisades Nuclear Plant current technical specifications (CTS) to improved technical specifications (ITS).
We have determined that '\\/lie require additional information to complete our evaluation of ITS Sections 1.0, 3.0, and 4.0. Please provide your response to the staff comments in the enclosure within 45 days of yolir receipt of this letter. The staff requests that you provide your response using the enclosed comment format, adding your responses where indicated in the enclosure.. Should you have any questions, please do not hesitate to contact me at (301) 415-1312 or Mary Lynn Reardon of the Technical Specifications Branch at (301) 415-1177.
Docket No. 50-255
Enclosure:
As stated cc w/encl: See next page Sincerely, ORIGINAL SIGNED BY Robert G. Schaaf, Project Manager
, Project Directorate 111-1 Division of Reactor Projects - Ill/IV Office of Nuclear Reactor Regulation DISTRl~UTION (w/encl):
W'©'~~9 PUBLIC PD#3-1Reading EAdensam (EGA1) 0 C ACRS B. Burgess, Riii M. Reardon DOCUMENT NAME: G:\\WPDOCS\\PALISADE\\PALITS30.RAI
~-
')'
r=:fOI I To receive a copy of this document, indicate in the box C=Copy w/o attachmenUenclosure E=Copy with attachmenUenclosure N = No copy OFFICE PM:PD31 NAME RSchaaf:d DATE Bit.A. 198 9808280197 980821 PDR
.ADOCK 05000255 P
PDR LA:PD31 CJamerso OFFIC1AL RECORD COPY
Mr. Nathan L. Haskell Consumers Energy Company cc:
Mr. Thomas J. Palmisano Site Vice President Palisades Plant 27780 Blue Star Memorial Highway Covert, Michigan 49043
- Mr. Robert A. Fenech, Sr Vice Pres Nuclear, Fossil, and Hydro Operations Consumers Energy Company 21.2 West Michigan Avenue Jackson, Michigan 49201 Arunas T. Udr}'s, Esquire Consumers Energy Company 212 West Michigan Avenue Jackson, Michigan 49201 Regional Administrator, Region Ill U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532-4351 Jerry Sarno, Supervisor Covert Township P. 0. Box 35 Covert, Michigan 49043 Office of the Governor P. 0. Box 30013 Lansing, Michigan 48909 U.S. Nuclear Regulatory Commission Resident Inspector's Office Palisades Plant 27782 Blue Star Memorial Highway Covert, Michigan 49043 Palisades Plant Drinking Water and Radiological Protection Division Michigan Department of Environmental Quality 3423 N. Martin Luther King Jr Blvd P. 0. Box 30630 CPH Mailroom Lansing, Michigan 48909-8130 Michigan Department of Attorney General Special Litigation Division 630 Law Building P.O. Box 30212 Lansing, Michigan 48909 August 1998
PALISADES IMPROVED TS REVIEW COMMENTS SECTION 1.0, USE AND APPLICATION 1.0-1 CTS 1.0, Shutdown Margin ITS 1.1, Shutdown Margin DOCA.13 JFD4 The insert to CTS markup, Shutdown Margin, states, "However, with all rods verified fully inserted by two independent means, it is not necessary to account for a stuck rod in the SOM calculation. With any rods not capable of being fully inserted, the reactivity worth of these rods must be accounted for in the determination of SOM; and". The STS markup and proposed ITS show the term "full length control rods" rather than "rods". This is inconsistent with the CTS markup and the DOC.
Comment: Revise the STS markup and proposed ITS to match the CTS markup and the DOC.
If the term "full length control rods" is to be used instead of "rods" in the ITS, provide a DOC and/or revise the JFD to justify the use of the term "full length control rods."
Consumers Energy Response:
1.0-2 ITS 1.1, Leakage DOCA.2 JFD2
The STS markup shows, "Leakage into the containment atmosphere from sources that are both specifically located and known ei#tef not to interfere with the operation of leakage detection systems ef and not to be pressure boundary Leakage; ef and". JFD 2 states that this is an editorial change for clarity or for consistency with the ITS Writer's Guide, and DOC A.2 states that the inclusion of the Leakage definition is an administrative change. While these statements are partially correct, the proposed ITS definition of Identified Leakage appears to be less restrictive then the STS definition.
Comment: Provide a DOC to address this change and/or revise the JFD to provide additional justification for the deviation from the STS.
Consumers Energy Response:
ENCLOSURE
PALISADES IMPROVED TS REVIEW COMMENTS SECTION 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY 3.0-1 STS LCO 3.0.4 and SR 3.0.4 JFD 6 JFD 6 states in part, "Rev. 1 to NUREG-1432 contains the option of limiting the Applicability of LCO and SR 3.0.4 to entry into a MODE or other specified condition in the Applicability in MOD~S 1, 2, 3, and 4. In addition, the Rev. 1 version of LCO and SR 3.0.4 would not prevent entry into MODES or other specified conditions in the Applicability that are part of any shutdown of the unit. However, to adopt the Rev. 1 version of LCO and SR 3.0.4, an evaluation must be performed on the existing technical specifications to determine where specific restrictions on MODE changes or Required Actions should be included in. individual LCOs to justify this change. For the Palisades plant there appears to be little benefit to adopt the Rev. 1 definition. In addition, since the process for determining where specific restrictions on MODE changes should occur has not been well defined, Palisades chooses not to adopt the allowances of Rev. 1 LCO and SR 3.0.4."
Comment: Provide an explanation of why there appears to be little benefit for Palisades to adopt the NUREG-1432, Rev. 1, definition.
Consumers Energy Response::
3.0-2 ITS LCO and SR 3.0.4 JFD 6 TSTF-103, Rev. 1 (Not Approved as of 8/21/98)
TSTF-103 ITS LCO 3.0.4 and SR 3.0.4 include TSTF-103 changes. JFD 6 states in part, "When Rev. 1 to NUREG-1432 was written, the wording in LCO and SR 3.0.4 was written to reflect the Rev. 1 allowances discussed above [see staff comment 3.0-1 above] without using brackets to indicate acceptable alternative wording if the Rev. 1 approach to implementing LCO and SR 3.0.4 was
- n'ot taken. To correct this, the industry owner's groups wrote TSTF-103 to add brackets to the areas which discussed LCO and SR 3.0.4 being only applicable in MODES 1, 2, 3, and 4; and provided alternative wording where the Rev. 1 version discussed "any unit shutdown." The proposed wording in the Palisades ITS for LCO and SR 3.0.4 is modeled after the changes made in TSTF-103 along with some proposed changes to TSTF-103 to correct some consistency errors. n Comment: TSTF-103 Rev. 1 has not been approved (as of August 21, 1998). If this TSTF remains unapproved at the time the Palisades review is complete and the Palisades Safety Evaluation (SE) is being prepared, the ITS will have to return to the CTS, or new justification for this change will need to be prepared.
Consumers Energy Response:
2
PALISADES IMPROVED TS REVIEW COMMENTS SECTION 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY 3.0-3 Markup of STS SR B 3.0.2 JFD 8 TSTF-52 (Not Approved as of 8/21/98)"
JFD 8 states, in part, "The proposed Bases for 3.0.2 is modified to reflect a change by the industry's owner's groups as discussed in [TSTF-52], which was generated to implement Option B of Appendix J. The current NUREG-1431, Rev. 1 Bases for SR 3.0.2 stated at the end of the paragraph "The 25% extension... ":
"An example of where SR 3.0.2 does not apply is a Surveillance with a Frequency of "in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions." The requirements of regulations take precedence over the TS. The TS cannot in and of themselves extend a test interval specified in the regulations. Therefore, there is a Note in the Frequency stating, "SR 3.0.2 is not applicable."
TSTF-52 (which has not been approved as of August 21, 1998) changes this sentence to state:
"An example of where SR 3.0.2 does not apply is the Containment Leak Rate Testing Program."
The proposed ITS will no longer reference 10 CFR 50, Appendix J, but will instead reference the Containment Leak Rate Testing Program in the Administrative Controls Section.
Comment: TSTF-52 has not been approved (as of August 21, 1998). If this TSTF remains unapproved at the time the Palisades review is complete and the Palisades Safety Evaluation (SE) is being prepared, the ITS will have to return to the CTS, or new justification for this change will need to be prepared.
Consumers Energy Response:
3
PALISADES IMPROVED TS REVIEW COMMENTS SECTION 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY 3.0-4 STS LCO 3.0.2 Bases ITS LCO 3.0.2 Bases JFD 12 TSTF-122 TSTF-122 is incorporated to revise the LCO 3.0.2 Bases to remove possible confusion. The NUREG-1432, TSTF-122 change states in part, "Additionally, if intentional entry into ACTIONS Alternative that would ftet result in redundant equipment being inoperable, alternatives should be used instead. Doing so limits the time both subsystems/trains of a safety function are inoperable and limits the time etftet= conditions exist which may result in LCO 3.0.3 being entered."
Comment: To comply with TSTF 122, the ITS Bases for LCO 3.0.2, 7th paragraph, the word "other should be deleted. The STS markup should also be revised to reflect this change.
Consumers En*ergy Response:
4
r PALISADES IMPROVED TS REVIEW COMMENTS SECTION 4.0, DESIGN FEATURES 4.0-1 ITS 4.3.2 Drainage DOCA.5 The proposed ITS, 4.3.2, Drainage specifies, "The spent fuel storage pool cooling system suction and discharge piping is designed and shall be maintained to prevent inadvertent draining of the pool below elevation 644 ft 5 inches. n The NUREG-1432 4.3.2 Drainage states, "The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation [23 ft].
DOC A.5 states in part, "The discharge piping is at 647' and contains a siphon breaker. The bottom of the suction piping is at elevation 644'5". Since these piping arrangements are permanent plant features, and no additional operational requirements have been imposed the inclusion of this information into the proposed ITS is considered to be an administrative change."
Comment: Revise the DOC or provide an appropriate JFD to address the plant':'specific spent fuel storage pool elevation.
Consumers Energy Response:
4.0.,2 ITS 4.3.3 Capacity JFD4 Proposed ITS 4.3.3, Capacity, is a new TS for Palisades Section 4.0. ITS 4.3.3 states, "The spent fuel storage pool and north tilt pit are designed and shall be maintained with a storage capacity limited to no more than 892 fuel assemblies."
JFD 4 relates to changes that reflect the facility specific nomenclature, number, reference, system description, or analysis description.
Comment: Provide a DOC for the addition of TS 4.3.3.
Consumers Energy Response:
5