ML18066A664

Proposed Tech Specs Re Surveillance Implementation

ML18066A664
Person / Time
Site:	Palisades
Issue date:	09/30/1999
From:	CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML18066A663	List: ML18066A662 ML18066A664
References
NUDOCS 9910060182
Download: ML18066A664 (12)

Text

ATTACHMENT 2 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 IMPROVED TECHNICAL SPECIFICATIONS PROPOSED LICENSE CONDITION SURVEILLANCE IMPLEMENTATION PROPOSED PAGES I

99100601821 990930 1 _

~DR --~~K~ 050~5 l _____ _ l

UNITED ST A TES NUCLEAR REGULATORY COMMISSION WASHINGTON, DC 20:555 - 0001 CONSUMERS ENERGY COMPANY DOCKET NO. 50-255 PALISADES PLANT FACILITY OPERATING LICENSE License No. DPR-20

1. The Nuclear Regulatory Commission (the Commission) has found that:

'y A. The application for a license filed by Consumers Power Company (CPCo)* complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act),

and 10 CFR Chapter I, and all required notifications to other agencies or bodies have been duly made; B. Construction of the Palisades Plant (the facility) has been completed in conformity with Provisional Construction Permit No. CPPR-25 and the application, as amended, the

- provisions of the Act; and the regulations of the Commission, and has* been operating under a provisional operating license since March 24, 1971; C. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission (except as exempted from compliance in Section 2.D. below);

I D. There is reasonable assurance that the activities authorized by this Facility Operating License can be conducted without endangering the health and safety of the public;

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E., CPCo* is technically qualified to engage in the activities authorized by this license, as amended, in accordance with 10 CFR Chapter I; .

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F. ~CPCo* has satisfied the applicable provisions of 10 CFR Part 140, "Financial Protection Requirements and Indemnity Agreements";

G. The issuance of this license will not be inimical to the common defense and security or to the health and safety of the public; H. The issuance of this license is in accordance with 10 CFR Part 51 and all applical;>le requirements have been satisfied; and, \.

I. The receipt, possession, and use of source, byproduct: and special nuclear material as authorized by this licen~e will be in accordance with 10 CFR Parts 30, 40, and 70.

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• **on March 11, 1997, the nam~ "Consumers Power Company" was changed to "Consumers Energy Company".

Amendment No. 4-74, 176

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2. Provisional Operating License No. DPR-20, dated March 24, 1971 as amended, is supers~ded in its entirety by Facility Operating License No. DPR-20 hereby issued to

• consumers Energy Company to read as follows:

A. This license applies to the Palisades Plant, a pressurized light water moderated and cooled reactor and electrical generating equipment (the facility). The facility is located in Van Buren County, Michigan, and is described in Consumers Energy Company's Updated Final Safety Analysis Report, as supplemented and amended, and in, Consumers Energy Company's Environmental Report, as supplemented and amended.

B. Subject to the conditions and requirements incorpor_ated ~erein, the Commission hereby licenses:

(1) Consumers Energy Company, pursuant to'section 104b of the Atomic Energy Act of 1954, as. amended, and 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities," to possess, use, and operate the facility in accordance with the limitations set forth in this license; ,

(2) .Consumers Energy Company, pursuant to the Act and 10 CFR Parts 40 and 70, to receive, possess, and use source and special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Updated Final Sa~ety Analysis.Report, as supplemented a*nd amended; *

(

(3) Consumers Energy C<;>mpany, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use byproduct, source, *and.special nuclear material as sealed sources for reactor startup, reactor instrumentation, radiation monitoring equipment calibration, and fission dete~tors in amounts as required; I

(4) Consumers Er)ergy Company, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or specialJnuclear material for sample analysis or instrument calibration,:/ or associated.

with radioactive apparatus or components; and -

}

(5) Consumers Energy Company, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct arid special nuclear materials as may be produced by the operations of the facility ..

C. This license shall be deemed to contain and is subject to all applicable provisions of the Act; to the rules, regulations, and orders of th_e Commission now or hereafter*in effect; and is subjec~ to the additional conditions specified or incorporated below:

(1) Consumers Energy Company is authorized to operate the facility at steady-state reactor core power levels not in excess of 2530 Megawatts thermal (100 percent rated power) in accordance with the. conditions specified herein.

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(2) The Technical Specifications contained in Appendix A, as revised through Amendment No. . , and the Environmental Protection Plan contained in Appendix B are hereby incorporated in the license. Consumers Energy Company shall operate the facility in accorqance with the Technical Specifications and the Environmental Protection Plan.

Amendment No. 474, 4-76,

3 (3) Consumers Energy Company shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility and as approved in the SERs dated 09/01 /78, 03/19/80, 02/10/81, 05/26/83, 07/12/85, 01/29/86, 12/03/87, and 05/19/89 and subject to the following provisions:

a. Consumers Energy Company may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

b. Consumers Energy Company may alter specific features of the approved fire protection program provided:

Such changes do not result in failure to complete the fire protection program as approved by the Commission. Consumers Energy Company shall maintain in auditable form, a current record of all such changes, including an analysis of the effects of the change on the fire protection program and shall make such records available to the Commission Inspectors upon request. All changes to the approved program shall be reported annually, along with the FSAR revision; and

• Temporary changes to specific fire protection features which may be necessary to accomplish maintenance or modifications are acceptable provided interim compensatory measures are implemented.

(4) Upon implementation of Amendment , the schedule for the performance of new

• and revised Surveillance Requirements (SRs) shall be as follows:

a. For SRs that are new in the amendment, the first performance is due at the end of the first surveillance interval that begins on the date of implementation of this amendment.

b. For SRs that existed prior to this amendment whose intervals of performance are being reduced, the first reduced surveillance interval begins upon completion of the first surveillance performed after implementation of this amendment.

c. For SRs that existed prior to this amendment that have modified acceptance criteria, the first performance is due at the end of the first surveillance interval that began on the date the surveillance was last performed prior to the implementation of this amendment.

d. For SRs that existed prior to this amendment whose intervals of performance are being extended, the first extended surveillance interval begins upon completion of the last surveillance performed prior to implementation of this amendment.

Amendment No. 4-74, 4-76, ff-7, 478, 4-79, 489, 484,-482,-483,-484,-485, 488,

4 D. The facility has been granted certain exemptions from the requirements of Section 111.G of Appendix R to 10 CFR Part 50, "Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979." This section relates to fire protection features for ensuring the systems and associated circuits used to achieve and maintain safe shutdown are free of fire damage. These exemptions were granted and sent to CPCo*

in letters dated February 8, 1983, July 12, 1985, and July 23, 1985.

In addition, the facility has been granted certain exemptions from Appendix J to 10 CFR Part 50, "Primary Reactor Containment Leakage Testing for Water Cooled Power Reactors." This section contains leakage test requirements, schedules and acceptance criteria for tests of the leak-tight integrity of the primary reactor containment and systems and components which penetrate the containment. These exemptions were granted and sent to CPCo* in a letter dated December 6, 1989.

These exemptions granted pursuant to 10 CFR 50.12, are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security. With these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.

E. Consumers Energy Company shall fully implement and maintain in effect all provisions of the Commission-approved "Palisades Plant Physical Security Plan," "Palisades Plant Suitability Training and Qualification Plan," and "Palisades Plant Safeguards Contingency Plan," and all approved amendments. Cons.umen~ Energy Company_ may make changes to these plans without prior Commission approval, if the changes do not decrease the safeguards effectiveness of the plans, in accordance with 10 CFR 50.54(p)(2).

F. Except as otherwise provided in the Technical Specifications or Environmental Protection Plan, the licensee shall report any violations of the requirements contained in Section 2.C of this license in the following manner: initial notification shall be made within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the NRC Operations Center via the Emergency Notification System with written follow-up within 30 days in accordance with the procedures described in 50.73(b),

(c), and (e).

G. Consumers Energy Company shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.

H. This license is effective as of the date of issuance and shall expire at midnight on March 14, 2007.

• FOR THE NUCLEAR REGULATORY COMMISSION Original Signed By: Thomas E. Murley Thomas E. Murley, .Director _

Office of Nuclear Reactor Regulation Attachments:

1. Appendix A - Technical Specifications

2. Appendix B - Environmental Protection Plan Date of Issuance: February 21, 1991

• On March 11, 1997, the name "Consumers Power Company" was changed to "Consumers Energy Company." Amendment No. 474, 4-76,

ATTACHMENT 3 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 ENGINEERED SAFETY FEATURES INSTRUMENTATION MEASURED DRIFT DATA

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FUNCTIONAL TEST EXTENSION ADDITIONAL INFORMATION During a telephone conference cali' on August 18, 1999, the NRC requested additional information related to the test data associated with the Engineered Safety Features.

Specifically, a summary of the data for the Pressurizer Low Pressure trip was requested to indicate that the drift did not exceed the drift value assumed in the error analysis performed for this parameter. The information requested is discussed below.

As previously discussed, the bistables used to initiate ESF actuations are not adjusted as part of the monthly functional testing. Further, these bistables will also not be adjusted as part of our proposed quarterly functional testing program. The bistables are, however, adjusted during the calibration performed at each refueling outage (18 month intervals). The acceptability of only adjusting these bistables during the calibration interval is provided below.

The attached table provides data taken for the*four Pressurizer Low Pressure trip bistables during the last 3 refueling cycles. For this trip setting, the Technical Specification.Allowable

• value is 1593 PSIA which corresponds to 13. 72 milliamps (ma). The data labeled as (Alf), is

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the as-found data collected at the end of the refueling cycle. The data labeled as (F) is the final data for the bistable trip setting following any adjustment made as part of th/e instrument loop calibration. Bistable drift would then be the difference between the as final (F) data and the as-found (A/F-) between refueling intervals. The worstcase change in the bistable trip .settirrn.

was -0.143 ma on channel PIA-0102ALL. This change occurred between *11/13/96 and 5/6/98.

Based on the instrument loop having a 40 ma range, the -0..143 ma change is equivalent, to

.. 358% of range. -

Based on vendor data provided for the trip bistables used in this application, th~ total uncertainty associated with the trip setpoint is .34 ma (0.85%). This value was used in the setpoint_error analysis for this parameter. Linearly extrapolating the worst case errors described in the preceding paragraph to account for a 22.5 (1.25 x 18) month calibration in~erval, *results in a total error of 0.179 ma (0.447%). This error is less than the total error assumed in the setpoint analysis and thus the loop is shown to operate within the error bounds used the analysis.

Similar data for each of the Engineered Safety Feature Actuation System instrument loops was reviewed with results similar to that shown for the pressurizer pressure loop. The data as discussed above shows that the ESF bistable trip units are very stable and that increasing the functional test interval for the Engineered Safety Feature Systems from monthly to quarterly will not cause th~ setpoint value to exceed the allowable value as calculated by the our'setpoint methodology.

Sheet1 Palisades Low Pressurizer Pressure Bistable Trip Data Milliamps (ma) I i I 6/21/1993(F) 6/22/1995(A/F) 7/4/1995(F) 11 /13/1996(A/F) 11 /13/1996(F) 5/6/1998(A/F) 5/6/1998(F)

PIA-0102ALL 14.192 14.25 14.2 14.28 14.243 14.1 14.16 PIA-0102BLL 14.255 14.22 14.262 14.258 14.19 14.08 14.2 PIA-0102CLL 14.193 14.14 14.141 14.137 14.14 14.04 14.19 PIA-0102DLL 14.175 14.185 14.183 14.11 14.16 14.19 14.14

ATTACHMENT 4 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 RISK IMPACT DISCUSSION CONTAINMENT COOLING EQUIPMENT LCOs

~SK IMPACT ASSESSMENT ITS CONTAINMENT COOLING LCOs The .P.~oposed Palisades Improved Technical Specifications ( ITS) requirements for Containment Spray System (CSS), Containment Air Coolers (CACs}, Component Cooling Water (CCW}, and Service Water System (SWS) differ from those in Current Technical Specifications (CTS).

The CTS Containment Cooling LCO groups the CSS pumps, CCW pumps, SWS pumps, and CACs together and allows only two of the listed pumps or coolers to be inoperable at one time.

The proposed ITS LCOs group CSS pumps and CACs together in one LCO, and address CCW and SWS in separate LCOs. As proposed, the ITS would allow multiple components to be inoperable at one time provided 100% of the post accident cooling capability was available.

Each of these LCO and Action Requirement arrangements is intended to:

1) Provide LCOs which require that sufficient operable equipment is available to provide the safety function (post accident containment heat removal) assuming a single active failure,

2) Allow continued operation, for a limited time, when the LCOs are not met, provided sufficient operable equipment is available to provide the safety function (without necessarily having the ability to cope with an additional single active failure), and

• 3)

• Assure that continued operation is not allowed if the safety function cannot be provided by operable equipment.

Since these proposed ITS allow more equipment to be inoperable at one time than the CTS do, the EOOS computer program was used to provide a risk comparison between the two. Palisades uses the EOOS computer program to quickly estimate the change in risk (core melt probability) for plant configurations necessary to perform planned maintenance and of plant conditions which develop due to equipment failures.

The EOOS safety assessments compare the extreme containment cooling equipment outages allowed by CTS with those that would be allowed by ITS. While numerous permutations of equipment outages are possible, two comparisons were made: 1) assuming that the maximum allowed containment spray related equipment was inoperable (thereby placing reliance on the containment air coolers), and 2) assuming that the maximum allowed containment cooler related equipment was inoperable (thereby placing reliance on the containment sprays).

The first EOOS assessment:

CTS: two CSS pumps inoperable (one in each train) RAW= 1.00 (No discernable change in risk)

ITS: two CSS pumps inoperable (one in each train},

!wo CCW pumps inoperable_ (one in each train)_, and . . .

one SWS pump inoperable RAW= 1.34 (Minor change in risk)

The second EOOS assessment:

CTS: two CACs inoperable RAW= 1.01 (Almost no discernable change in risk)

ITS: Three CACs inoperable, two CCW pumps inoperable (one in each train),

two SWS pumps inoperable (one in each train), and One CCS pump. RAW= 5.40 (Moderate change in risk)

In addition to the above comparisons, assessments were performed on several plant configurations with various combinations of containment cooling related components assumed t0 be inoperable.

T~ese additional risk assessments provide a group of situations with which the above assessments can .b~ compared. The results of these EOOS evaluations are provided in the attached table. The Allowed Outage Time (AOT) is tabulated for each situation where CTS or ITS allow continued operation.

Plant experience shows that having two major safety related components become inoperable at one time is quite rare. Voluntarily removing multiple safety related components from service at one time is not common practice, and is cautioned against in plant procedures. The probability of having five (or eight!) inoperable components at one time, as evaluated here, would be extremely small.

Both the CTS and the ITS allow equipment to be removed from service for maintenance or testing.

During maintenance planning, prior to removing equipment from service, plant procedures require performance of a safety assessment of the proposed plant configuration. Palisades Administrative Procedure 4.02, Control of Equipment, provides guidance on how and when to perform a Maintenance Rule safety assessment. All planned and emergent activities receive a safety assessment in accordance with Maintenance Rule guidance.

The plant 13-week maintenance schedule is developed to identify system/train outages (windows) for all plant systems. The baseline 13-week schedule was reviewed by the PSA group and found to have an acceptable impact on nuclear safety. During the scheduling of planned maintenance or testing activities, an attempt is made to conform to the 13-_week system/train windows. However, there are instances when scheduled activities need to occur outside the planned system/train windows. Therefore, an additional safety assessment is performed for all planned maintenance or testing activities.

The safety assessment is performed the week before the planned activities are scheduled. A safety assessment is performed for each day and indicates whether there are specific sequences of activities that are required (return component A to service prior to removing component B, etc.). If no specific sequences are required, then the activity may occur anytime during the scheduled day.

An additional safety assessment is performed for emergent work. Emergent work is performance of activities that were not scheduled including performance of maintenance or test activities on a different day than scheduled if equipment in the plant becomes unavailable (breaks). The new safety assessment evaluates all equipment out of service (including the emergent work) to determine the current safety impact. No new activities are started until a safety assessment has been performed.

Any safety assessment that results in a high safety impact (RAW>10 from EOOS) for planned activities, requires General Manager, Plant Operations approval to proceed. If the plant is in' a configuration when emergent work occurs and the safety assessment result in a high safety impact (RAW>10), then no additional equipment is allowed to be removed from service without the _

approval of the General Manager, Plant Operations. At that time, the plant staff would evaluate the situation and schedule repair work to reduce the impact on nuclear safety in the most effective manner (EOOS can prioritize return to service actions).

The relatively small risk impact of the proposed ITS requirements and the maintenance controls implemented under the maintenance rule support the conclusion that the proposed "functional" action statement requirements are acceptable.

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.. ,Ill-*~ . , Comoarison - Containment Coolin CTS ALLOWANCE AOT RAW ITS ALLOWANCE AOT RAW DEPENDANCE ON CACs:

Spray P54*A&B 24 H 1.00

... *t Spray P54*A&B, AND ccw P52*A&B 72 H 1.34 sws p7.9 DEPENDANCE ON SPRAY:

CA Cs VHX 1&2 24 H 1.01 CA Cs VHX*1,2,&3, AND Spray P54*A ccw P52*A&B 72 H 5.4 sws P7*A&B COMPARATIVE EVENTS ccw P52*A 7D 1.00 72 H 1.00 P52*A&B 24 H 1.00 72 H 1.00 P52*A,B,&C 1.49 1.49 Spray P54*A 7D 1.00 72 H 1.00 P54*B 7D 1.00 72 H 1.00 P54*A&B 24 H 1.00 72 H 1.00 P54-A,B,&C 166 166 sws P7-A 7D 1.00 72 H 1.00 P7-B 7D 1.34 72 H 1.34 P7-A&B 24 H 1.35 72 H 1.35 P7-A&B & CV-1359 24 H 1.75 1.75 CA Cs 1 CAC 7D 1.00 72 H 1.00 CACS 2CACs 24 H 1.01 72 H 1.01 3CACs 2.27 72 H 2.27 LPSI P67-A 24 H 1.00 7 D# 1.00 Batt. D01 24 H 1.79 24 H 1.79 DG 1-2 7 D* 2.99 7D 2.99 HPSI P66-A 24 H 7.1 72 H 7.1 DG 1-1 & 1-2 2H 15.4 2H 15.4

• 7 DAYS PER MONTH TOTAL FOR BOTH #With TSTF 58 3