ML20076N034
| ML20076N034 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/26/1994 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20076N031 | List: |
| References | |
| NUDOCS 9411090145 | |
| Download: ML20076N034 (4) | |
Text
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-y-t UNITED STATES 2
S NUCLEAR REGULATORY COMMISSION f
WASHINGTON, D.C. 20555 4 001
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION F,[ LATED TO AMENDMENT NO. 162 TO FACILITY OPERATING LICENSE NO. OPR-20 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET NO. 50-255
1.0 INTRODUCTION
By letters dated November 15, 1991, February 22, March 11, April 7, and August 23, 1994, Consumers Power Company (CPC) submitted a proposed Technical Specification (TS) change request for its Palisades Plant. The proposal included completely rewritten instrumentation operability requirements and its bases, and extensively changed the contents and format of the TS. The proposed changes add operability requirements for certain instruments to accommodate its additional functions, and also add operability requirements for those instruments which currently have only surveillance requirements in the plant TS.
The changes include the addition of new limiting conditions for operations (LCOs) and surveillance requirements, limitation on the time for which an instrument channel can be bypassed, improved correlation between the LC0 actions and surveillance requirements, and corrective actions to be completed if the operability requirements of the specification is not met.
The letter dated August 23, 1994, contained six revised TS pages with changes necessitated by intervening amendments. Thus, the letter did not change the l
initial proposed determination of no significant hazards consideration l
published in the Federal Feaister on May 25, 1994 (59 FR 27052).
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2.0 EVALUATION The existing Palisades TS was developed prior to issuance of standard TS, and is therefore, a custom written document which includes various non-conservative actions and outage times without any formal safety analysis to justify the non-conservatism. Additionally, post-accident monitoring (PAM) instrumentation is not provided with a separate LCO, and various other instruments are listed only for surveillance without corresponding LCOs. The proposed changes include rewriting of the entire instrumentation LCOs and surveillance requirements with corresponding detailed bases.
The rewritten TS and bases follow the new improved STS format.
The proposal also adds PAM instrument LCOs and corresponding surveillance requirements.
In addition to the format and editorial changes, the staff review of the licensee's submittals identified the following major changes to the Palisades TS.
9411090145 941026 ADOCK 05000255 l
PDR PDR P
i A.
Definitions were rewritten to more closely match the STS definitions or to clarify the plant design.
Some definitions were deleted, such as " degree of redundancy," because those definitions were no longer applicable due to the proposed changes to the TS.
The staff found the rewritten definitions to be specifically applicable to the proposed changes, comparable to the STS definitions, and therefore, acceptable.
B.
The engineered safety features (ESF) initiation instrumentation LC0 (Section 3.16) was rewritten in the STS format with necessary corrections, such as adding action statements and correcting the existing pressurizer low pressure setting limits to the applicable allowable values.
Steam generator level channels were added to start auxiliary feedwater pumps on low level.
The staff found the licensee's justification for these changes in its no significant hazard analysis acceptable.
The existing instrumentation and control systems LCO (Section 3.17) has four groups of instruments for the plant protection systems (i.e., reactor protection system (RPS), ESF, isolation, and other safety feature functions).
The proposal changed this LCO into four separate LCOs, each with separate applicability and action requirements. A new LCO for PAM instrumentation was added to the TS as a fifth instrumentation LCO, while the existing alternate shutdown system instrumentation LC0 (Section 3.25) has been rewritten in the STS format and added to TS Section 3.17 as a sixth instrumentation LCO.
The proposed changes to the TS also include rewritten instrumentation surveillance requirements (Section 4.17) for each of the corresponding six instrumentation LCOs in Section 3.17.
The
" minimum degree of redundancy" requirement of the existing TS has been removed, and " required number of channels" has been added for each of the functions in the RPS, ESF, isolation, and other safety feature functions LCOs.
The action statements and permissible conditions are also extensively changed to remove inappropriate requirements, and to replace them with the STS requirements.
Time limits on actions for an inoperable channel have been proposed where no action is currently required.
Additionally, LCOs are added for those instrument channels which currently have only a surveillance requirement in the TS.
Our review of these changes indicated that specifying the applicability, actions, and completion times, when either some or none are currently specified, will ensure the instrumentation availability when its safety function is required and will allow maintenance or testing when the instrument operability is not required. The completion time for an action removes ambiguity regarding the allowed outage time, and is consistent with the STS requirements.
Specifying a required action when the specification is not met, removes the ambiguity of the existing TS in
l situations where plant operation continued with an inoperable RPS channel in bypass for an unlimited time period, or where entry into cold shutdown could be mcde when that action was not specified.
The information provided by the " degree of redundancy" in the existing TS bases was ambiguous and caused excessive confusion when compared to the proposed
" minimum operable channels" requirement consistent with the current STS.
This information is now provided in a more useful form in each LC0 associated basis section.
Adding an LCO for PAM instrumentation channels did not change any existing limitation or requirement as defined in the plant final safety analysis report. Most of the specification is comprised of new requirements which are the same as those in the STS.
Specifically, PAM instrumentation functional unit operability requirements are transferred to the proposed TS Section 3.17-4 from the plant final safety analysis report and are the same as the STS except those for the emergency feedwater flow indication channels which are classified as Type D, Category 2, and thus, are not required to be included in the PAM instrumentation TS. The staff, therefore, finds the proposed PAM instrumentation LC0 and corresponding TS operability requirements to be acceptable.
The proposed surveillance requirements for plant instrumentation systems are a rewritten version of the existing specifications which provide standardized terminology and better coordination with the LC0 sections.
The licensee proposed deletion of the following five surveillance requirements of the existing specifications. Of these, the first three were not required by the safety analyses and, therefore, should not have been in the TS.
The fourth surveillance requirement deleted was an operability verification of an alarm that itself was not required to be operable.
Deletion of the fifth surveillance requirement was previously approved on a gen ric basis in Generic Letter 93-05.
1.
Performance of a calorimetric upon receipt of a flux-delta alarm.
2.
Verification of diesel generator starting prior to each start up.
3.
Surveillance testing on portable radiation monitors located in the emergency plan kits.
4.
Channel functional test on a wide range pressurizer level alarm.
5.
Surveilicace testing of safety injection tank level and pressure instruments.
Based on review of the licensee's submittals, the staff concludes that the proposed changes to the Palisades instrumentation and control TS are consistent with the plant licensing basis defined in the final safety analysis report, and the rewritten LCO's and surveillance requirements are more explicit regarding required actions, and correspond to the new revised STS.
The staff, therefore, finds the proposed changes to be acceptable.
3.0 STATE CONSULTATION
i In accordance with the Commission's regulations, the Michigan State Official was notified of the propsed issuance of the amendment. The Michigan State Official had no comments.
4.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant
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increase in individual or cumulative occupational radiation exposura. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public 4
comment on such finding (59 FR 27052). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b), no environmental impact statement l
or environmental assessment need be prepared in connection with the issuance of the amendment.
I.-
5.0 CONCLUSION
i The staff has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common j
defense and security or to the health and safety of the public.
j Principal Contributor:
- 1. Ahmed, HICB Date: October 26, 1994
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