Text

Application for Amend to License DPR-20,reflecting Capabilities of Installed CR Ventilation Equipment & Emulate Std Tech Specs,C-E Plants,Per NUREG-1432 Requirements for Sys
	ML18067A671
Person / Time
Site:	Palisades
Issue date:	09/03/1997
From:	Bordine T; CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18067A672	List: ML18067A671; ML18067A673;
References
	RTR-NUREG-0737, RTR-NUREG-1432, RTR-NUREG-737, TASK-3.D.3.4, TASK-TM GL-83-37, NUDOCS 9709090107
	Download: ML18067A671 (9)
	v • d • e

A CMS Energy Company 111omas t:. Bordlno Manager Licensing September 3, 1997 U S Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT TECHNICAL SPECIFICATION CHANGE REQUEST - CONTROL ROOM VENTILATION A request for a change to the Palisades Technical Specifications (TS) which revises the Control Room Ventilation LCO, TS 3.14, and the associated surveillance requirements, Table 4.2.3, is enclosed. This change is desired to update the TS to reflect the capabilities of the installed Control Room Ventilation Equipment and to emulate the Standard Technical Specifications, Combustion Engineering Plants - NUREG 1432 (STS) requirements for that system.

On November 19, 1984, Consumers Power Company submitted a Technical Specifications change request in response to Generic Letter 83-37 and NUREG-0737, Item III.D.3.4. That change request proposed, in part, to replace the Technical Specification 3.14 requirements for the Control Room Ventilation System because "our existing technical specification requirement for the Control Room Ventilation System applies to a system that was completely replaced during the refueling outage". That change request proposed requirements, similar to those proposed here, which were appropriate for a two train system. The proposed specification was to be applicable at all times.

The Control Room Ventilation specification actions applicable during cold shutdown proposed in that change request were revised on February 28, 1986 in a supplement to the November 19, 1984 TS change request.

On January 24, 1989, at NRC request, Consumers Power Company requested withdrawal of that change request and several others to reduce the backlog of open TS change requests then on the docket. In our withdrawal request we stated "The changes will be incorporated into administrative controls and be factored into the RTS [Restructured (or Improved) Technical Specifications]

submittal." The Control Room Ventilation System requirements are contained in the Palisades Operating Requirements Manual. The NRC stated the change request had been withdrawn in a letter dated May 15, 1989.

It is requested that this change become effective sixty days after approval.

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SUMMARY

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

CC Administrator, Region III, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Enclosure

ENCLOSURE 1 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 TECHNICAL SPECIFICATION CHANGE REQUEST CONTROL ROOM VENTILATION SYSTEM

CONSUMERS ENERGY 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. to this change request contains the proposed Technical Specifications and Bases pages. The changes are marked with a vertical line in the margin. Attachment 2 contains the current Technical Specifications and Bases pages marked to show the proposed changes. These pages show a line drawn through proposed deletions and shading for proposed additions.

The following abbreviations are used in this change request:

AOT Allowed Outage Time CRHVAC Control Room Ventilation (Heating, Ventilation, &Air Conditioning)

LCO Limiting Condition for Operation RPS Reactor Protective System SR Surveillance Requirement STS Standard Technical Specifications (NUREG 1432)

TS Current Palisades Technical Specifications TMM Thermal Margin Monitor The proposed changes are described below. Each change is classified as one of the following categories:

ADMINISTRATIVE - A change which is editorial in nature, which only involves movement of requirements within the TS without affecting their technical content, or clarifies existing TS requirements.

MORE RESTRICTIVE - A change which only adds new requirements, or which revised an existing requirement resulting in additional operational restriction.

I. The following Changes are Proposed:

A. Table of Contents page ii has been revised to show the proposed new sections of Section 3.14.

Change A does not alter any TS requirements and is therefore classified as Administrative.

B. The "Applicability" and "Objective" sections of TS 3.14 have been replaced with equivalent information in the Bases sections. These sections do not contain any operating limitations or restrictions.

They provide only background information and have been replaced with extensive bases discussions.

Change B does not alter any TS requirements and is therefore classified as Administrative.

2 C. TS Action 3.14a has been replaced by a revised condition description for TS Action 3.17.1.6:

Currently TS Action 3.14a states:

If the control room air temperature reaches 120°F, immediate action shall be taken to reduce this temperature or to place the reactor in a hot shutdown condition.

Revised Action 3.17.6.1 states (underlined text was added):

If any action required by 3.17.1 is not met AND the associated completion time has expired, or if the number of OPERABLE channels is less than specified in the "Minimum OPERABLE Channels", or if Control Room Temperature exceeds 90°F:

a) The reactor shall be placed in HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and b) The reactor shall be placed in a condition where the affected equipment is not required, within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

New Bases information supporting this revised requirement has been added to pages B 3.17-5, B 3.17-7, and B 3.17-35.

The results of this proposed change would be to:

1) Reduce the control room temperature at which a shutdown must be initiated from 120°F (which was specified in the initial issue of the Palisades TS, and was appropriate for the initially installed control room equipment) to 90°F (which is acceptable for the currently installed equipment, specifically the TMM).

This change was requested by the NRC in a March 28, 1990 letter to Consumers Power Company, entitled "THERMAL MARGIN MONITOR (TMM) AUDIT FOLLOW-UP". On December 7, 1990, Consumers Power Company committed to incorporate this 90°F limit into the Restructured (Improved) Technical Specification Conversion.

2) Specify a time for reaching Hot Shutdown, rather than stating "immediate action shall be taken . . . to place the reactor in a hot shutdown condition." The time specified is unchanged from current TS and is typically used in TS action statements requiring the plant to be placed in Hot Shutdown. The alternate allowance to reduce control room temperature, rather than shutdown, is provided by LCD 3.0.2 which states, in part "If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the action requirements is not required."

3) Specify that, not only must Hot Shutdown be reached, but that the reactor be placed in a condition where the RPS is not required. This is appropriate since, depending on plant conditions, the RPS could still be relied upon in Hot Shutdown.

4) More closely relate the control room temperature limit, and its associated Action, with the RPS (the equipment associated with

3 the restriction). Change E, below, proposes moving the Control Room Temperature verification from the ventilation surveillance section to the RPS surveillance section.

Change C reduces the allowable control room temperature, specifies an explicit completion time, where none is currently stated, and requires additional corrective actions in addition to those currently required. Change C is, therefore, classified as More Restrictive.

D. TS 3.14b has been replaced with two LCOs, 3.14.1 and 3.14.2. These

.proposed LCOs emulate the STS LCOs for control room ventilation, LCOs 3.7.11 and 3.7.12. The SRs for control room ventilation remain in Table 4.2.3.

Required Equipment: The existing LCO requires only one system consisting of two fans and a filter system. Proposed LCO 3.14.1 requires these same items as part of the requirement for two redundant trains for control room air filtration; each train consisting of a pre-filter, a heater, a High Efficiency Particulate Air (HEPA) filter, two banks -0f activated charcoal absorbers for removal of gaseous activity (principally iodine), a second HEPA filter, and a fan. In addition, a second LCO, 3.14.2, has been proposed which requires two redundant cooling trains, each consisting of heating coils, cooling coils, instrumentation, and controls to provide for control room temperature control. These are the functions required in STS and are assumed in the accident analyses to assure control room habitability.

LCO Applicability: The existing LCO has no explicit applicability; existing Actions imply the applicability is "above Cold Shutdown."

The proposed LCOs are explicitly stated to be applicable above Cold Shutdown, and are also explicitly stated to be applicable during Refueling Operations, movement of irradiated fuel assemblies, and movement of a fuel cask in or over the Spent Fuel Pool. These are the conditions under which the accident analyses assume functioning of the Control Room Ventilation System.

Required Actions: Existing actions allow both fans (ie both trains) to be inoperable for 3~ days, if restoration is not achieved in that time, the plant is required to be in Cold Shutdown in the next 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (ie a total AOT of 120 hours0.00139 days 0.0333 hours 1.984127e-4 weeks 4.566e-5 months ). The required actions in each proposed LCO, for both trains being inoperable during operation above Cold Shutdown, require immediate entry into LCO 3.0.3, as is done in STS.

In addition, required Actions emulating those in STS are provided in each proposed LCO for conditions where: 1) one required train is inoperable, and 2) two trains are inoperable during Cold Shutdown or under other applicable conditions.

Change D would require additional equipment to be operable, expand the existing applicability, and provide additional, more restrictive Actions. Therefore, change D is classified as More Restrictive.

4 E. TS Table 4.2.3 SR number 3, verification of control room temperature, has been moved, to the RPS SR Table 4.17.1. The remaining SRs remain in Table 4.2.3.

Change E does not alter any TS requirements and is therefore classified as Administrative.

II. Analysis of No Significant Hazards Consideration Consumers Energy Company finds that this proposed Technical Specifications change involves no significant hazards and accordingly, a no significant hazards determination per 10 CFR 50.92(c) is justified.

As discussed in Section I, each proposed change has been classified as Administrative or More Restrictive.

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

"More Restrictive" changes only add new requirements, or revise existing requirements to result in additional operational restrictions. The TS, with all "More Restrictive" changes incorporated, will still contain all of the requirements which existed prior to the changes. Therefore, the "More Restrictive" changes cannot involve a significant increase in the probability or consequences of an accident previously evaluated.

"Administrative" changes make wording changes which clarify existing TS requirements, without affecting their technical content. Since "Administrative" changes do not alter the technical content of any requirements, they 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?

"More Restrictive" changes only add new requirements, or revise existing requirements to result in additional operational restrictions. The TS, with all "More Restrictive" changes incorporated, will still contain all of the requirements which existed prior to the changes. Therefore, the "More Restrictive" changes cannot create the possibility of a new or different kind of accident from any previously evaluated.

"Administrative" changes make wording changes which clarify existing TS requirements, without affecting their technical content. Since "Administrative" changes do not alter the technical content of any requirements, they cannot create the possibility of a new or different kind of accident from any previously evaluated.

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

"More Restrictive" changes only add new requirements, or revise existing requirements to result in additional operational restrictions. The TS, with all "More Restrictive" changes incorporated, will still contain all of the requirements which existed prior to the changes. Therefore, the "More Restrictive" changes cannot involve a significant reduction in a margin of safety.

"Administrative" changes make wording changes which clarify existing TS requirements, without affecting their technical content. Since "Administrative" changes do not alter the technical content of any requirements, they cannot involve a significant reduction in a margin of safety.

III. Conclusion The Palisades Plant Review Committee has reviewed this Technical Specifications 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.

CONSUMERS ENERGY COMPANY TECHNICAL SPECIFICATION CHANGE REQUEST CONTROL ROOM VENTILATION SYSTEM To the best of my knowledge, the content of this Technical Specification change request, which revises the Control Room Ventilation LCOs and surveillance, is truthful and complete.

~ hOTi1aSCB01fle Manager, Licensing Sworn and subscribed to before me this~ day of ~2 1997.

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

My commission expires August 26, 1999

ML18067A671

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SUMMARY

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