ML18067A619

Provides Addl Info to Support Completion of Review of TS Change Request Re Crane & Heavy Loads

ML18067A619
Person / Time
Site:	Palisades
Issue date:	06/27/1997
From:	Bordine T CMS ENERGY CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9707070325
Download: ML18067A619 (9)

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A CMS Energy Company 111amas c. Batdlns Manager Licensing June 27, 1997 U S Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT TECHNICAL SPECIFICATION CHANGE REQUEST - CRANE AND HEAVY LOADS ADDITIONAL INFORMATION On December 6, 1995, Palisades submitted a Technical Specifications change request proposing relocation of the Crane and Heavy Loads section. Additional submittals on that subject were provided on October 10, 1996 and January 10, 1997. This letter provides additional information to support completion of the review of the subject change request.

The subject change request proposed relocating several Technical Specifications (TS) requirements to the Operating Requirements Manual (ORM).

As stated in item 2 of our October 18, 1996 letter, the requirements of TS 3.21 have been added to the ORM. The ORM is comprised of two Standing Orders, Standing Order 54 and Standing Order 62, the Crane and Heavy Load Requirements were included in Standing Order 54 as Section 3.21. The affected pages of Standing Order 54 have been attached.

Subsequent discussions with the NRC staff suggested that removal of the subject requirements from TS could only occur if those requirements had been added to the FSAR to assure that they would be subject to the requirements of 10 CFR 50.59. In our January 10, 1997 letter on this subject we stated that the TS 3.21 Crane and Heavy Load requirements would be added to the FSAR prior

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to the implementation of the subject TS change request.

During the time period between our former submittals on this subject and the present, the NRC has provided additional guidance on relocation of TS requirements to Licensee controlled documents. Rather than adding the Crane and Heavy Loads requirements to the FSAR, as discussed in our January 10, 1997 letter, changes have been made in Palisades FSAR Revision 19, which 1) describe the ORM, and 2) incorporate the ORM into the FSAR by reference.

These FSAR changes assure that the Crane and Heavy Loads requirements in the ORM are controlled by the requirements of 10 CFR 50.59.

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• 27780 Blue Star Memorial Highway

• Cove; I, Ml 49043

• Tel: 616 764 2913

• Fax: 616 764 2490

• 2 The text of the revised FSAR section is:

12.3.3 OPERATING REQUIREMENTS MANUAL {ORM)

The ORM contains equipment 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 is incorporated into the FSAR by reference and will be revised in the same manner as the FSAR. Changes to the ORM will become effective after approval by the General Manager - Plant Operations.

Revision 19 of the Palisades FSAR was submitted to the NRC, in accordance with 10 CFR 50.71, on June 27, 1997.

SUMMARY

OF COMMITMENTS This letter establishes no new commitments. It notifies the NRC that the commitment made in our January 10, 1997 letter to add the TS 3.21 Crane and Heavy Load requirements to the FSAR has been accomplished by 1) adding those requirements to the ORM and 2) incorporating the ORM into the FSAR.

Thomas C. Bordine Manager, Licensing CC Administrator, Region III, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades

ATTACHMENT CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 TECHNICAL SPECIFICATION CHANGE REQUEST CRANE AND HEAVY LOADS ADDITIONAL INFORMATION Operating Requirements Manual Crane and Heavy Load Requirements 6 Pages

To

• Shift Supervisors, Palisades Control Room, Palisades

• STANDING ORDER 54 Revision 43 Page 1 of 2

. I From Shift Operations Superviso~ CONSUMERS ENERGY Date May 19, 1997 Subject PALISADES PLANT- OPERATING REQUIREMENTS.

MANUAL cc NRC Office, Palisades DWKaupa, Palisades DWRogers, Palisades BNYoung, Palisades APPROVED a'L.i '~f)' = -

General Manager, Plant Operations Plant modifications and commitments made to the NRC have resulted in numerous proposed changes to the Palisades Technical Specifications. While we are not authorized to change the Technical Specifications, we can implement operational requirements which are more restrictive or more conservative than those in the Technical Specifications. To maintain systems and equipment affected by the proposed changes OPERABLE, supplementary requirements which must be followed, in addition to the Technical Specifications, are prescribed in Attachment 1 to this Standing Order.

These supplementary requirements are arranged in numerical order corresponding to the associated Technical Specification. No attempt has been made to reproduce entire "as proposed" pages. Where a specific section or specification number from the Technical Specifications is included in these supplementary requirements, the wording contained in these supplementary requirements must be followed in addition to the wording of the Technical Specifications.

• STANDING ORDER 54 Revision 43 Page 2 of 2 All requirements included in this document are to be treated in all respects, except the reporting of violations, as if they are Palisades Technical Specification requirements. While deviation from the Palisades Technical Specifications can only be authorized by the NRC, deviation from these supplementary requirements is allowed, provided:

The deviation does not create a situation which is less restrictive than allowed by the Palisades Technical Specifications, and A written Seven Question 1 OCFR50.59 Safety Evaluation is generated, reviewed and recommended for approval by the Plant Review Committee, and approved by the General Manager, Plant Operations or his alternate.

In the case of these supplemental requirements, there is no requirement to report violations to the NRC. However, these supplementary requirements are to be treated in all other respects as if they were issued by the NRC, unless there is an approved deviation (as described above).

All changes to these supplementary requirements require:

A Commitment Tracking System search, A written Seven Question 1 OCFR50.59 Safety Evaluation, and Review and recommendation for approval by the Plant Review Committee, and Approval by the General Manager, Plant Operations.

The Safety Evaluation performed for the change shall also include a written determination as to whether or not the change creates a situation which is less restrictive than allowed by the Palisades Technical Specifications.

The changes made in this revision to these supplementary requirements are listed on page 1.

2

• STANDING ORDER 54 ATTACHMENT 1 Revision 43 OPERATING REQUIREMENTS MANUAL Notes:

( 1) These requirements supplement the equipment operability and surveillance requirements of the Technical Specifications. They have been reviewed by PRC.

(2) Check Commitment Tracking System prior to changing or deleting any of these requirements, to avoid failing to meet an NRC commitment.

(3) These requirements may be changed, through the administrative control processes, but the change process shall include a Seven Question Safety Evaluation.

(4) These requirements are not Technical Specifications. Neither failures to operate within these requirements nor plant shutdowns, made solely due to these requirements, must be reported to the NRC.

(5) Changes made in this revision are noted by bars in the right margin.

These changes are listed on page 1 .

(6) The Operating Requirements Manual (ORM), Standing Order 54, is incorporated into the FSAR by reference and will be revised in the same manner as the FSAR. Changes to the ORM shall become effecrtive after approval by the General Manager, Plant Operations.

3

Standing Order 54

. Revision 43

• Attachment 1 Page 15 of 27 3.21 CRANE OPERATION AND MOVEMENT OF HEAVY LOADS Applicability Applies to limitations in crane operation and the movement of heavy loads over the 649' level of the auxiliary building and inside containment. A heavy load is a load, other than a fuel assembly, which weighs more than 1300 lbs.

Objective To minimize the probability of and the consequences of a heavy load drop.

Specification 3.21.1 INSIDE CONTAINMENT

a. Heavy loads shall not be moved over the primary coolant system if the temperature of the coolant or the steam in the pressurizer exceeds 225 °F.

b. Heavy loads shall not be moved unless the potential for a load drop is extremely small as defined by Generic Letter 85-11 or an evaluation in compliance with section 5.1 of NUREG 0612, Control of Heavy Loads in Nuclear Power Plants has been completed.

3.21.2 OVER THE 649' LEVEL OF THE AUXILIARY BUILDING The surface of the floor adjacent to the spent fuel pool is at the 649' level of the auxiliary building. The spent fuel pool is made up of two (2) zones.

They are the main pool zone and the north tilt pit zone.

a. Heavy loads shall not be moved over fuel stored in the main pool zone.

b. Heavy loads shall not be moved over areas of the main pool zone which do not contain fuel unless the fuel stored in the main pool zone has decayed a minimum of 30 days when the charcoal filter is operating, or the fuel stored in the main pool zone has decayed a minimum of 90 days when the charcoal filter is not operating.

c. Heavy loads shall not be moved over the north tilt pit zone unless the fuel stored in the north tilt pit zone has decayed a minimum of 22 days when the charcoal filter is operating; or, the fuel in the north tilt pit zone has decayed a minimum of 77 days when the charcoal filter is not operating.

Standing Order 54

. Revision 43

• Attachment 1 Page 16 of 27

d.

• Heavy loads shall not be moved over the 649' level of the auxiliary building unless:

( 1) The fuel storage building crane interlocks are 0 PERABLE or they are bypassed and the crane is under administrative control of a supervisor, and (2) No fuel handling operations are in progress.

e. Loads weighting more than 25 tons shall not be moved over the main pool zone unless an evaluation in compliance with Section 5.1 of NUREG 0612, has been completed.

f. Heavy loads shall not be moved unless the potential for a load drop is extremely small as defined by Generic Letter 85-11 or an ev.aluation in compliance with Section 5.1 of NUREG 0612 has been completed.

g. The Fuel Pool Building Crane shall not be used to move material past the fuel storage pool when its interlocks are inoperable.

Basis NUREG 0612 defines a heavy load as a load which weights more than a fuel assembly and its handling tool. The lightest Palisades fuel assemblies weigh approximately 1298 lbs and the heaviest weigh approximately 1375 lbs.

The handling tool weights 60-70 lbs . For conservatism, loads weighting more than 1300 lbs, except for fuel assemblies, are classified as heavy loads.

Heavy loads are not allowed over the pressurized primary coolant system to preclude dropping objects which could rupture the boundary of the primary coolant system allowing loss of coolant and overheating of the core.

Prohibiting movement of heavy loads over fuel stored in the main pool zone minimizes the criticality and radiological effects of a load drop.

Heavy loads are allowed over the fuel stored in the north tilt pit zone because the maximum number of fuel bundles which can be stored in that zone is relatively small and the north tilt pit lies under the only possible safe load path for moving heavy loads into and out of containment without passing over the main pool zone.

Requiring that the spent fuel pool crane interlocks are OPERABLE ensures that heavy loads or the unloaded crane will not qrift over or be inadvertently moved over fuel stored in the main pool area.

Standing Order 54 Revision 43

• Attachment 1 Page 17 of 27 Specific decay times with and without the charcoal filters, operating are necessary to ensure that heavy loads are moved within analyzed conditions.

The charcoal filter is operating when at least one Fuel Handling Area exhaust fan is drawing suction through the charcoal filter and the Fuel Handling Area ventilation system is in the refueling mode.

Assuring that no fuel handling operations are in progress while heavy loads are being moved allows operator attention to be focused on the heavy load movement.

The objectives of the Guidelines of Section 5.1 of NUREG 0612 are to assure that (l) the potential for a load drop is extremely small, or (2) for each area addressed, the following evaluation criteria are satisfied:

( 1) Release of radioactive material that may result from damage to spent fuel based on calculations involving accidental dropping of a postulated heavy load produce doses that are well within 10 CFR Part 100 limits of 300 rem thyroid and 25 rem whole body; (2) Damage to fuel and fuel storage racks based on calculations involving accidental dropping of a postulated heavy load does not result in* a configuration of the fuel such that Kett is larger than 0.95; (3) Damage to the reactor vessel or the spent fuel pool based on calculations of damage following accidental dropping of a postulated heavy load is limited so as not to result in water leakage that could .

uncover the fuel, (makeup water provided to overcome leakage shall be from a borated source of adequate concentration); and (4) Damage to equipment in redundant or dual safe shutdown paths, based on calculations assuming the accidental dropping of a postulated heavy load, will be limited so as not to result in loss of required safe shutdown functions.

Generic Letter 85-11 defines the potential for a heavy load drop as extremely small when a heavy load is moved in compliance with the Guidelines of Section* 5.1.1 of NU REG 0612.