ML20129E555
| ML20129E555 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/26/1996 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20129E543 | List: |
| References | |
| NUDOCS 9610010108 | |
| Download: ML20129E555 (4) | |
Text
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y UNITED STATES j
,g NUCLEAR REGULATORY COMMISSION i
2 WASHINGTON, D.C. ennan mi O
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I SAFETY EVALUATION BY THE OFFICE OF NVCLEAR REACTOR REGULATION BELATED TO AMENDMENT NO.172 TO FACILITY OPERATING LICENSE NO. DP CONSUMERS POWER COMPANY PALISADES PLANT DOCKET N0. 50-255 l
1.0 INTRODUCTION
1 By letter dated February 6,1996, Consumers Power Cmpmy (the licensee) requested an amendment to the Technical Specificatiora (TS) appended to Facility Operating License No. DPR-20 for the Palisades Plant. The proposed amendment would delete the requirement to parform alternate train testing (referred to in the licensee's submittal as " cross-train" testing) to demonstrate that redundant safety-related components are operable when the emergency core cooling system (ECCS) and containment cooling system are found to be inoperable or are removed from service for maintenance.
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2.0 EVALUATIOE The licensee proposed to delete requirements from the ECCS (TS 3.3) and i
containment cooling system (TS 3.4) limiting conditions for operation which require redundant train components to be tested when a required component becomes inoperable.
TS 3.3.2b states:
One low pressure safety injection pump may be inoperable provided the pump is restored to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The other low pressure safety injection oumo shall be tested to demonstrate operability orior to initiatina repair of the inoperable cump.
TS 3.3.2c states:
One high pressure safety injection pump may be inoperable provided the pump is restored to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Ihg other hiah oressure safety injection oumo shall be tested to 4
demonstrate operability orior to initiatina repair of the inoperable oumo.
TS 3.3.2f states:
Any valve, interlock or pipe associated with the safety injection and shutdown cooling system and which is not covered under 3.3.2e 9610010108 960926 PDR ADOCK 05000255 P
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above but, which is reouired to function during accident conditions, may be inope<able for a period of no more than 24.
hours.
Prior to initiatina repairs. all valves and interlocks in i
the system that provide the duolicate function shall be tested to l
demonstrate operability.
TS 3.4.2 states:
During power operation, one af the components listed in Specification 3.4.1 above may be inoperable orovided that the correspondina redundant components shall bi tested to demonstrate operability.
If the inoperable component !; not restored to operability within 7 days, the reactor shall be placed in a hot shutdown condition.
TS 3.4.3 states, in part:
During power operation, the requirements of Specification 3.4.1 may be modified to allow a total of two of the components listed in Section 3.4.la or b to be inoperable at any one time orovided the emeraency diesel connected to the ocoosite enaineered safeauards bus is started to demonstrate operability.
The redundant component or system on the other bus shall be tested before initiatina maintenance on the inoperable components.
If the operability of at least one of the two inoperable components is not restored within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the reactor shall be placed in a hot shutdown condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
1 (TS 3.4.1 a and b specify components associated with each train of the containment cooling system. These components include the containment air coolers, and the service water, component cooling water, and containment spray pumps.)
TS 3.4.5 states:
Any valve, interlock or pipe associated with the containment cooling system which is not covered under Specification 3.4.4 above and which is required to function during accident conditions may be inoperable for a period of no more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> orovided that orior to initiatina repairs. all valves and interlocks in the system that provide the duplicate function shall be tested to demonstrate operability.
The licensee proposed to delete the underlined phrases from the above TS. The licensee stated that the required periodic surveillance testing has been shown by operating experience to provide adequate assurance that the redundant equipment remains operable. The licensee also stated that testing of some equipment requires rendering the equipment inoperable, which could result in a loss of safety function when this testing is performed while the redundant system is inoperable.
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, I The licensee proposed to replace the underlined phrase in TS 3.4.2 with "for a l
period of up to seven days", and to replace the underlined phrase in TS 3.4.3 with, "for a period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />".
These are editorial revisions which reiterate the allowed outage times of the associated TS.
As articulated in an NRC staff memorandum (C. I. Grimes to R. A. Capra, et al., dated April 10,1992), alternate train testing requirements were included in early TS to provide a positive demonstration that a loss of safety function had not occurred. This requirement was not included in later TS when it was realized by the staff that the added assurance of redundant system operability was not sufficient to justify the loss of safety function which occurs during the test, provided that required periodic surveillance testing is current and there is no known reason to suggest that the alternate train is inoperable.
The NRC staff's current position with respect to alternate train testing is reflected in NUREG-1432, " Standard Technical Specifications, Combustion Engineering Plants," (STS), which does not require alternate train testing.
The STS considers operability of the alternate train of safety equipment to be adequately demonstrated by performance of the required periodic surveillance tests.
The staff concludes that adequate assurance of component and system operability is provided by periodic surveillance testing, and the elimination of the specified requirements to perform alternate train testing is acceptable.
3.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Michigan State official was notified of the proposed 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 corrponent located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements.
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 l-offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.
The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding (61 FR 28611). Accordingly, the amendment meets the eligibility criteria for l
categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need 1
be prepared in connection with the issuance of the amendment.
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5.0 CONCLUSION
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
1 4-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 defense and security or to the health and safety of the public.
Principal Contributor:
R. Schaaf Date: September 26, 1996 1
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