ML18066A325

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Application for Amend to License DPR-20,deleting CVCS Operability Requirements Currently in LCOs 3.2 & 3.17.6 & Associated Testing Requirements in SRs 4.2 & 4.17
ML18066A325
Person / Time
Site: Palisades Entergy icon.png
Issue date: 11/09/1998
From: Haskell N
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18066A326 List:
References
NUDOCS 9811180072
Download: ML18066A325 (9)
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A CMS Energy Company Palisades Nuclear Plant Tel: 616 764 2276 27780 Blue Star Memorial Highway Fax: 616 764 2490 Covert, Ml 49043 Nathan L. Maskell Director, Licensing November 9, 1998 U S Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT TECHNICAL SPECIFICATIONS CHANGE REQUEST - RELOCATION OF eves REQUIREMENTS A request for a change to the Palisades Technical Specifications is requested to delete the Chemical and Volume Control System (CVCS) operability requirements currently in LCOs 3.2 and 3.17.6, and associated testing requirements currently in Surveillance Requirements 4.2 and 4.17. *These requirements do not meet any of the criterion of 10 CFR 50.36(c)(2) (ii). The subject requirements have been added to the Palisades Operating Requirements Manual, which is incorporated into the FSAR by reference, and therefore subject to the requirements of 10 CFR 50.59.

Palisades submitted a Technical Specifications change request (TSCR) to convert to Improved Technical Specifications on January 26, 1998. That change request also requests relocation of the CVCS Technical Specifications 1/

requirements. However, the conversion to ITS will not be accomplished in time 1 to support the upcoming planned maintenance on one section of concentrated boric acid piping. That maintenance may well require more time than allowed by the current allowed outage time.

This Technical Specifications change is desired in order to allow performance!]--()<'.?~

of that maintenance without incurring the potential for a plant shutdown solely due to the inoperability of a system which is not safety-related (as defined in 10 CFR 50.2).

TS 3.2.2 requires three flow paths for boric acid makeup to the charging pump suction, two from the concentrated boric acid tanks (a gravity feed and a pumped feed) and one from the safety injection refueling water tank, to be 9011100012 901 f o9 -

PDR ADOCK 05000255

2 operable whenever the reactor is critical. One section of the two heat traces on the concentrated boric acid gravity feed flow path has failed. Both channels of heat tracing are considered operable, with one channel degraded.

Repair to that heat trace channel requires removal of the thermal insulation, which will result in the gravity feed line becoming inoperable.

TS 3.2.3 and 3.2.3c allow a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed outage time for the gravity feed line. Prejob planning has estimated that the repair will take about 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> to complete. Since the gravity feed flow path is currently operabl~, and there are two additional flow paths for boric acid makeup available, repairs have been delayed until they can be performed with*assurance that unforseen difficulties will not necessitate a shutdown required by Technical Specifications. The repair of the boric acid gravity flow path heat tracing is in our plan for the next forced outage of sufficient length. If an extended maintenance outage is not needed, we would like to complete this maintenance on line prior to the onset of hot weather in the 1999 Summer season. Since these proposed changes were also included in our Improved Technical Specification conversion request submitted on January 26, 1998, which has been under review since that time, we do not foresee this request causing a significant increase in NRC staff workload. Therefore, we request that review of this TSCR be scheduled to allow approval no later than February 1, 1999. It is also requested that this change to the Technical Specifications become effective upon approval.

A copy of this letter has been sent to the appropriate official of the State of Michigan.

SUMMARY

OF COMMITMENTS This letter establishes no new commitments and makes no revisions to existing commitments.

/; 'd~lfaJJ!b N than L. Haskell CC Administrator, Region III, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Dennis R. Hahn, Michigan Department of Environmental Quality Enclosures

t CONSUMERS ENERGY COMPANY TECHNICAL SPECIFICATIONS CHANGE REQUEST To the best of my knowledge, the content of this Technical Specifications change request, which Relocates the Technical Specifications requirements for the Charging Pumps and the Concentrated Boric Acid System to the Operating Requirements Manual, is truthful and complete.

Director, Licensing Sworn and subscribed to before me this Cj'JJ..- day of ){?~ 1998.

~~~~~

Alora M. Davis, Notary Public Berrien County, Michigan (Acting in Van Buren County, Michigan)

My commission expires August 26, 1999

    • J

ENCLOSURE 1 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 TECHNICAL SPECIFICATIONS CHANGE REQUEST RELOCATION OF eves REQUIREMENTS

CONSUMERS POWER COMPANY Docket 50-255 Technical Specifications Change Request License DPR-20 It is requested that the Technical Specifications contained in the Facility Operating License DPR-20, Docket 50-255, for the Palisades Plant be changed as described below.

The following abbreviations are used in this change request:

CVCS Chemical and Volume Control System LCO Limiting Condition for Operation ORM Operating Requirements Manual SR Surveillance Requirement STS Standard. Technical Specifications (NUREG 1432)

TS Palisades Technical Specifications to this change request contains the proposed TS and Bases pages.

The changed areas are marked with a vertical line in the margin. Attachment 2 contains the current TS and Bases pages marked to show the proposed changes by a line drawn through proposed deletions and shading for proposed additions. contains the pages of the ORM which contain the relocated CVCS requirements.

I. The following Changes are Proposed:

The LCOs, Action Statements, and SRs associated with the Charging Pumps and with the Concentrated Boric Acid System have been deleted.

Identical requirements have been added to the ORM. The ORM has been incorporated into the FSAR by reference, thereby assuring that changes to the ORM will be made in accordance with the requirements of 10 CFR 50.59.

The deleted TS requirements are:

LCO 3.2, "CHEMICAL AND VOLUME CONTROL SYSTEM", including:

Specifications 3.2.1 and 3.2.2 Action Statement 3.2.3 SR Table 4.2.1, Item 4 SR Table 4.2.2, Item 9.

LCO 3.17.6, Item 14, "Cone Boric Acid Tank Lo Level Alarm", including:

Action Statement 3.17.6.14 SR Table 4.17.6, Item 14.

2 TS pages 3-25m and 3-29 have been revised to show the deletion of pages 3-26 through 3-28. The Bases for TS Sections 3.17 and 4.17 have been revised to delete reference to the deleted requirements.

TS Section 3.2, CHEMICAL AND VOLUME CONTROL SYSTEM, specifies the requirements for the charging pumps and the concentrated boric acid system. In addition to the requirement found in TS Section 3.2, other requirements are found throughout the Palisades TS which relate to operability of the concentrated boric acid system. These include:

TS 3.17.6.14 requires that with the Cone. Boric Acid Tank Lo Level Alarm inoperable that the level in the Boric Acid Tank must be verified to be within limits each 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

TS Table 3.17.6 Item 14, Concentrated Boric Acid Tank Lo Level Alarm, requires one channel/tank when the reactor is at HOT STANDBY and above.

TS Table 4.2.1 Item 4 requires that the Concentrated Boric Acid Tanks be!

tested for Boron Concentration on a Monthly basis.

TS Table 4.2.2 Item 9 specifies that the Boric Acid Heat Tracing is verified to be at the proper temperature on a daily basis. Heat tracing is used on piping which transports concentrated boric acid to ensure that the solution remains in the liquid form.

TS Table 4.17.6 Item 14, BAT Low Level Alarm, requires a CHANNEL FUNCTIONAL TEST every 18 months.

Neither functioning of the charging pumps nor addition of concentrated boric acid is currently assumed in any accident or transient analyses. The initial Palisades Main Steam Line Break (MSLB) analyses assumed addition of concentrated boric acid by the charging pumps. This addition was necessary to limit the extent of the return to power which was predicted for a MSLB late in core life. The MSLB was reanalyzed when new steam generators were installed, and again for the most recent core reload. These analyses did not assume charging pump operation or concentrated boric acid addition. The new steam generators incorporate a flow restrictor in the outlet nozzle which reduces the maximum steam flow rate sufficiently to show satisfactory analytical results without the eves system. Therefore, the eves system is not required to limit DNBR during an MSLB event.

The initial Palisades SBLOCA analysis was developed using a comparative technique based on a SBLOCA analysis for a reference plant. The analysis for the reference plant assumed charging pump operation for inventory addition. A Palisades specific SBLOCA analysis was performed prior to fuel Cycle 13. This

3 new analysis did not assume charging pump operation. Therefore, the eves system is not required to mitigate an SBLOeA event.

The initial Palisades Volume Control tank Rupture (VeTR) and radiological consequences of Failure of Small Lines Carrying Primary Coolant Outside Containment (SMLBOC) credited charging pump operation in order to preclude loss of pressurizer inventory and subsequent reactor trip on low pressure.

The Cycle 14 VCTR and SMLBOC analyses were performed assuming an event generated iodine spike, thereby removing reliance on charging. Therefore, the eves system is not required to mitigate the VCTR or SMLBOC events.

The Palisades Steam Generator Tube Rupture (SGTR) event is performed to conservatively determine the Part 100 exclusion area boundary and the eight-hour Low Population Zone doses based on both event generated and pre-accident iodine spikes. As such, a conservative plant response is assumed,* including a gradual cooldown and depressurization of the primary coolant system over an eight hour period. Since offsite power is also assumed lost, a method to gradually reduce PCS pressure must be assumed to perform the analysis.

Palisades could utilize either the Power Operated Relief Valves (PORVs) or auxiliary spray to control the pressure reduction. For purposes of the

  • analysis, the depressurization was assumed to be controlled using aux spray, fed by the charging system, over the entire 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period. This method of depressurization was chosen because it was available in the model utilized by the vendor supplying the analysis and quantifies the bounding off-site doses.

A corresponding conservative pressure profile could also be obtained by utilizing the PORVs, however use of the PORVs allows the operators to reduce pressure much more quickly, resulting in lower offsite doses. While the design of the Auxiliary spray flow path components do not meet single failure criteria, that flow path is considered to be redundant to the PORV flow path, whose components are safety grade and do meet single failure criteria. Since the bounding offsite doses meet the criteria of 10 CFR 100, the eves system is not required to mitigate the consequences of a SGTR event.

The requirements which are proposed to be relocated to the ORM do not meet any of the criteria specified in 10 eFR 36(c)(2)(ii):

A. None of the instrumentation addressed by the relocated requirements are used for, nor is capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary.

B. As discussed above, none of the relocated requirements addresses a process variable,* design feature, or operating restriction that is an initial condition of a design basis accident or transient.

4 C. As discussed above, none of the relocated requirements address a structure, system, or component that is part of a primary success path in the mitigation of a design basis accident or transient.

D. The Chemical Volume Control System is not a significant contributor to risk.

Therefore, the Chemical and Volume Control System does not meet any criteria of 10 CFR 50.36(c) (2) (ii) and will be relocated from the Palisades TS to the Operating Requirements Manual.

II. Analysis of No Significant Hazards Consideration Consumers Power Company finds that this proposed TS change involves no significant hazards and accordingly, a no significant hazards determination in accordance with 10 CFR 50.92(c) is justified.

Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed changes delete certain TS requirements which do not meet the criteria of 10 CFR 50.36(c)(2)(ii), but identical requirements have been added to a document (the ORM) controlled under 10 CFR 50.59.

10 CFR 50.59 specifically prohibits changes to the facility as described in the safety analysis report, and to procedures described in the safety analysis report "if the probability of occurrence or the consequences of an _accident or malfunction of equipment important to safety previously evaluated in the safety analysis report may be increased". Since the conditions which limit changes performed under 50.59 are more restrictive than the conditions which define changes considered to involve a significant hazards consideration, moving of a requirement from the TS to a document which is controlled under 50.59 cannot involve a significant increase in the probability or consequences of an accident previously evaluated.

Do the proposed changes create the possibility of a new or different kind of accident from any previously evaluated?

The proposed changes delete certain TS requirements which do not meet the criteria of 10 CFR 50.36(c)(2)(ii), but identical requirements have been added to a document (the ORM) controlled under 10 CFR 50.59.

5 10 CFR 50.59 specifically prohibits changes to the facility as described in the safety analysis report, and to procedures described in the safety analysis report if a possibility for an accident or malfunction of a different type 11 than any evaluated previously 'in the safety analysis report may be created".

Since the conditions which limit changes performed under 50.59 are more restrictive than the conditions which define changes considered to involve a significant hazards consideration, relocation of a requirement from the TS to a document which is controlled under 50.59 cannot create the possibility of a new or different kind of accident from any previously evaluated.

Do the proposed changes involve a significant reduction in a margin of safety?

The proposed changes delete certain TS requirements which do not meet the criteria of 10 CFR 50.36(c)(2)(ii), but identical requirements have been added to a document (the ORM) controlled under 10 CFR 50.59.

10 CFR 50.59 specifically prohibits changes to the facility as described in the safety analysis report, and to procedures described in the safety analysis report if the margin of safety is reduced. Since the conditions which limit changes performed under 50.59 are more restrictive than the conditions which define .changes considered to involve a significant hazards consideration, relocation of a requirement from the TS to a document which is controlled under 50.59 cannot involve a significant reduction in a margin of safety.

III *. Conclusion The Palisades Plant Review Committee has reviewed this TS Change Request and has determined that proposing this change does not involve an unreviewed safety question. Further, the change involves no significant hazards consideration. This change has been reviewed by the Nuclear Performance Assessment Department.

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