ML20012E866

Safety Evaluation Supporting Amend 130 to License DPR-20

ML20012E866
Person / Time
Site:	Palisades
Issue date:	03/23/1990
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20012E864	List: ML20012E863 ML20012E866
References
NUDOCS 9004060472
Download: ML20012E866 (6)

Text

y

?

.. V e su,

[s o

t; WITED$Y'Til 4

. M

.o

'h NUCt.F AR REGULATORY CCMMIS$10N e

• l$

I susMiev0 tolv, D. C. e0M6 J

54.%....y

}

SAFETY [ VALUATION SY $ 0FFICE OF NUCLEAR REACTOR REGULATION n

i RELATED TO AM[NDMINT NO.13010 PROVISIONAL OPERATING LICENSE NO. OPR 20 PALISADES PLANT DOCKET NO. 50-255 t

1.0 INTRODUCTION

L By letter dated April 3, 1989, Consumers Power Company (CPCo), the licensee, proposed an amendment to Provisional Operating License No. OPR-20 for the N11sades Plant.

The proposed amendment would change the plant Technical Specifications (TSs) based on the recommendations provided by the staff in Generic Letter (GL) 87 09 related to the applicability of limiting conditions for operations (LCO) of TS 3.0 and the surveillance requirements of TS 4.0.

Specifically, the licensee has requested the following revisions to the plant TS by adding Sections 3.0.4, 4.0.3, 4.0.4 and 4.0.5 as follows?

Specificathn 3.0.4 is revised to define when its provisions apply; i.e., when the cffetted action statements permit continued operation for an unlimited time period, vice defining when the provisions do rot apply.

Specification 4.0.3 is added to incorporate a 24-hour delay in implementing action requirements due to a missed surveillance when the action requirements provide a restoration time that is less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Specification 4.0.4 is added to clarify that this provision shall not prevent passage through or to plant conditions as required to comply with action requirements.

b Specification 4,0.5 is added to provide conformance of the Palisades Plant Technical Specifications to the St.andard Technical Specificati ns and to clarify the definition of the frequencies of required surveillance tests.

This new specification includes requirements previously addressed in Specification 4.3 and adds appropriate requirements for inservice testing of valves.

The portions of Specification 4.3 superseded by Specification 4.0.5 are deleted.

TS Table 3.17.1, 4.1.1, and 4.1.2 are revised to identify operational conditions z

during which certain reactor protection system instrumentation is required to be

[

operable, and when associated instrument checks are required.

These changes are

(

needed to assure consistency with the proposed revision to Section 4.0.

C CPCo has also requested several additional changes as follows:

(1) add note (g) to Items 1 to 6 and 8 to 10 of Table 3.17.3

"(g) Required operable if any clutch power supply is energized."

+

(2) add note (h) to Item 7 of Table 3.17.1

"(h) Automatically bypassed below 15% power."

9004060472 900323 PDR ADOCK 05000255 i

P PDC nl m

..m p

-2 i

i (3) add note (7) to items 1.a. and 13.4 of Table 4.1.1. and add note I

at end of Table

)

• (7) Required if the reactor is critical."

l t

(4) addnote(8)toitems4.aand5.aofTable4.1.1.andaddnoteat end of Table.

• (8) Required when PCS is,,!!00 psia."

r (5) Delete note 4 for items Ib and 24 of Table 4.1.2, and add new note l

(4) for Item la (channel check, shif t surveillance).

Add note at end of Table.

"(4) Required when PCS is. 1500 psia."

l i

(6) Revise Specification 4.3 as follows:

l i

Delete items a, b, c, and d.

Remove asterisk from ltems h and i and remove asterisk footnote, i

2.0 E','A l p AT 10N Specification 3.0.4 GL 87-09 recognizes, in part, that $pecification 3.0.4 unouly restricts facility operation when conformance to the action requirements provides an acceptable i

level of safety for continued operation in any operational condition.

For an LCO that has action requirements permitting continued operation for an unlimited period of time, entry into an operational condition or other specified condi.

tion of operation should be permitted in accordance with those action l

requirements. The restricticn on change in operational condition or other i

specified cerditions should apply only where the action requirements establish a specified time interval in which the LCO must be met or a shutdown of the f acility would be required or where entry into that operational condition would result in entry into an action statement with such time contraints.

hetever, nothing in the staff position stated in GL 87-09 should be interpreted as endorsing or encouraging picnt startup with inoperable equipment. The GL 87-09 itself states that startup with inoperable equipment thould be the exception rather than the rule.

CPCo bes indicated assurance that the remedial measures prescribed by the action requirements for each change involving TS 3.0.4 is consistent with the plant licensing basis.

Further, CPto has proposed an additional TS change to define a rtw Plant Review Conrnittee (pRC) responsibility.

The proposed change.

submitted to the NRC by letter dated December 18, 1989, would require that all exceptions to TS 3.0.4 be reviewed by the PRC prior to changing plant operating conditions. The PRC review would provide assurance that the exception to TS 3.0.4 would not create an unreviewed safety question nor create a safety hazard.

The staff will review this proposed TS change apart from the changes proposed

• by the April 3, 1989, application.

CPCo has not proposed any associated changes that affect plant configuration,

~,

setpoints, operating parameters, or operator-equipment interface.

l

W.

\\

i

- o. 6, l

3 The staff finds acceptable the proposed revision to TS 3.0.4 Specification 4.0.3 l

i In GL 87-09, the staff stated that it is overly conservative to assume that systems or components are inoperable when a surveillance requirement has not been performed, because the vast niajority of surveillances demonstrate that i

systems or components in fact are operable.

Because the allowable outage time I

limits of some action requirements do not provide an appropriate tine limit for l

performirg a missed surveillance before shutdown requirements apply, the TS r

should include a time limit that would allow a delay of the required action to permit the performance of the missed surveillance.

This ttre limit should be based on considerations of plant conditions, adequate

[

planning, unavailability of personnel, the time required to perform the surveillance, as well as the safety significance of she delay in completion of i

the surveillance. After reviewing possible limits, the staff concluded that, based on these considerations, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would be an acceptable time limit for l

completirp a missed surveillance when the allowable outage times of the action i

requiren.ents are less than this time limit or when shutdown action requirements t

apply. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time limit would balance the risks associated with an l

allowance for completing the surveillance within this period against the risks r

associated with the potential for a plant upset and challenges to safety systems when the alternative is a shutdown to comply with action requirenents before the surveillance can be completed.

This limit does not waive compliance with Specification 4.0.3.

Under Specification 4.0.3, the failure to perform a surveillance requirement will i

continue to constitute notumpliance with the operability requirements of an LCO and to bring into play the applicable action requirements, j

Based en the above, the staff finds acceptable Specification 4.0.3 as proposed.

I Frecification 4.0.4 1

I TS 4.0.a prohibits entry into a reactor operating condition or other specified conditien until all required surveillances have been performed. This could l

cause an interpretation problem when plant operating condition changes are r

required in order to comply with action requirements.

Specifically, two possible conflicts between TSs 4.0.3 and 4.0.4 could exist. The first conflict arises because TS 4.0.4 prohibits entry into an operational condition or other speci-fied cotidition when surveillance requirements have not been performed within the

'i specificd surveillance interval. The resolution to this conflict involves a clarification to TS 4.0.3 to permit a delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the application l

of the action requirements, as explained above, and a statement in TS 4.0.4 to allcw passage through or to operational conditions as required to comply with ection requirements.

The second potential conflict between T5s 4.0.3 and 4.0.4 arises because an exception to the requirements of 4.0.4 is allowed when surveillance requirements can only be completed af ter entry into an operational l

condition.

How.ever, af ter entry into this condition, the requirements of TS 4.0.3 may not be met because the surveillance requirements may not have been perforned within the allowable surveillance interval.

l

CF 1

il 0

-.o o,

.s t

9-4 (FCo proposes to resolve these conflicts by adding T5 4.0.4 which would specify that ;!) entry into a reactor operating condition 'er other specified condition shall not be made unless the Surveillance Requirement (s) associated with a Limiting Condition of Operation has been perforned within the stated surveill.

ance interval or as otherwise specified, and (2) that this provision shall not prevent passage through or to plant conditions as required to comply with action requirements, j

In GL 87 09 the staff has clarified that: (a)itisnottheintentof4.0.3 that the actien requirem6nts preclude the >erfor1 nance of surveillances allowed i

under any exception to TS 4.0.41 and (b) tiet the delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in 15 4.0.3 for the applicability of action requirerents provides an appropriate titte limit for the completion of surveillance requirements that become applic.

l oble as consecuence of any exception to TS 4.0.4.

Therefore, the staff finds t

the proposed TS 4.0.4 acceptable.

Specification.4_.0_.S l

prcrosed TS 4.0.5 would establish the requirement that inservice inspection of ASME Code Class 1, 2, and 3 components and inservice testing of ASHE Coce Class l

1, 2, and 3 puttps and valves shall be performed in accordance with a periodic.

ally updated version of $cction XI of the ASME t' oiler and Pressure Yessel Code ard Addenda as required by 10 CTR 50.55a.

These requirements would apply, except when relief has been provided in writing by the Comission, This proposed specification includes clarificatien of the frequencies for per.

forrning the inservice inspection and testing activities required by Section XI of the ASPE Boiler anc Pressure Yessel Coct and applicable Addenda. Thib clarification is proposed to ensure consistency in surveillance intervals e

thrnughout the Technical Specifications and to remove anbiguities relative to thv f recuencies for performing the required inservice inspection and testing activities.

t!nder the terms cf this specification, the more restrictive requirements of the i

Technical Specifications take precedence over the ASME Boiler and Pressure l

Vessel Code and applicable Addenda. The requirements of Specification 4.0.4 to perforit surveillance activities before entry into a reactor operating condition or other specified condition takes precedence over the ASME Boiler and pressure Yessel Code provision which allows pumps and valves to be testr.d up to one week after return to normal operation.

The Technical Specification definition of ecerable does not allow a grace period before a component, that is not capable of performing its specified function, is declared inoperable and takes precedence over the ASKE Eoiler 6nd pretsure Vessel Code provision which allows l

a valve to be incapable of performing its specified function for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> l

before being declared inoperable.

1 i

The staff finds !pecification 4.0.5 acceptable.

1 1

1 i

[;f 7 j

• no,..

j w.

t

{igelienenus therstes CPCo heti proposed several changes which are of an editorial nature, or for the purpose of clarification, or to remove unnecessary requirements. The proposed changes and our evaluation follow.

3.

A footnote indicating that the operability requirement is applicable i

g when any clutch power supply is energized is proposed to be added to Table 3.17.1. The footnote would relate to all items of the Reactor l

Protection System (RPS) identified in the table except item 7 Loss of load.

(valuation This proposed change would add applicability requirements where pre-viously none existed to define when equipment is allowed to be out of l

service. The addition of the footnote would add a condition when the ecuipment coulo be inoperable similar to that which is allowed in the Standard Technical Specifications for Combustion Engineering Pressurized WaterReactors,NUREG0212(Rev2). The staff finds this proposec addition acceptable.

2.

A footnote indicating that item 7. Loss of Load, is automatically bypassed below IST power is proposed to be odded to Table 3.17.1.

j Evaluation The autoratic bypass always has been a design feature of the RPS.

Therefore, this change is acceptable.

T 3.

A footnote indicating that the surveillance requirernent is l

6pplicable when the reactor is critical is proposed to be added to Table 4.1.1.

The footnote would relate to iteras 1.a and 13.a (Power Pange Safety Channels surveillance checks, and Delta T Power l

channels surveillance checks).

Eveluation The addition of this footnote wculd add a condition when the equiprent l

surveillance would not be required which is similar to that which is allowed in the Standard Technical Specifications for Combustion l

Er.gtneerir.g Pressurized Water Reactors, NUREG-0212 (Rev 2). The staff l

finds this proposed addition acceptable.

1 4

A footnote indicating that the surveillance requirernent is applica-I ble when the Primary Coolant System pressure is greater than 1500 psia is proposed to be added to Table 4.1.1, item 4.a (Thermal Margin / Low Pressurizer Pressure check) ard item 5.a (High Pressurizer Pressure check) and Table 4.1.2, item 1.a (Low Pressure SIS Initia-I tion). The f ootnote added to Table 4.1.2 replaces existing Footnote (4) which no lenger has significance since it referred to a 1981 refueling outage surveillance deferral.

• o,0 o.

o o

i

.C.

i Evaluation The lower range of the pressurizer pressure instrumentation is 1500 psia, therefore, the staff finds these proposed changes acceptable 5.

I'roposed revisions to TS 4.3 would delete Specification 4.3.s through 4.3.d, and would delete asterisks from $pecifications 4.3.h and 4.3.1 and the associated footnote.

Evaluation l

New TS 4.0.5 would cover the existing requirements of TS 4.3.a through 4.3.d. and the footnote to T$s 4.3.h and 4.3.1 relates to the 1981 rtfueling outage and is no longer of significance.

Therefore, the staff finds that with the incorporation of proposed TS 4.0.6, the proposed deletions are acceptable.

7 3.0 FI:Y1R0t;t4Ef4TAL EONSIDERATION These amendments involve changes to a reouirement with respect to the instal.

lation or use of a facility conponent located within the restricted area as defir.ed in 10 CFR Part 20 and changes to the surveillance requirements. The staff has determined that these amendments involve ne significant increase in l

the an.ounts, and no significant change in the types, of any effluents that i

n.ay be released offsite and there is no significant increase in individual or i

cumulative occupational radiation exposure.

The Commission has previously l

issued a proposed finding that these amendnents involve no significant hazards consiceration and there has been no public coment of such finding.

Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuantto10CFR51.22(b),noenvironmental mpact statement or environmental assessment need be prepared in connection with the issuance of this amendment, t

4.0 MGLUSION The staff has concluded, based on the consideration discussed above that: (1) be endangered by operation in the proposed manner, (2) y of the public w there is reasonable essurance that the health and safet such activities will be l

conducted in etmpliance with the Commission's regulations and 1

oftheseamendmentswillnotbeinimicaltothecommondeYensea(3)theissuan nd security nor the the health and safety of the public, 1

Frincipal Contributor:

A. 5. liasciantonio, P031 A. W. DeAgazio, PD31 Dated: March 23. 1990 i

1 i

)

.