ML20149C044
| ML20149C044 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/01/1988 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20149C030 | List: |
| References | |
| REF-GTECI-A-03, REF-GTECI-A-04, REF-GTECI-A-05, REF-GTECI-SG, TASK-A-03, TASK-A-04, TASK-A-05, TASK-A-3, TASK-A-4, TASK-A-5, TASK-OR GL-85-02, GL-85-2, NUDOCS 8802090050 | |
| Download: ML20149C044 (4) | |
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT N0.110 TO PROVISIONAL OPERATING LICENSE N0. DPR-20
_ CONSUMERS POWER COMPANY PALISADES PLANT DOCKET N0. 50-255 INTRODUCTION By application dated January 19, 1988, Consumers Power Company (the licensee) requested changes to the Technical Specifications to delete the secondary water chemistry limits in Specification 3.18, along with surveillance require-ments in Table 4.2.1, and to replace them with program requirements in Section 6, the administrative section of the Technical Specifications.
These changes are required in order to implement the use of boric acid addition to the secondary steam generator water to minimize steam generator corrosion and denting. The licensee's consultant recommended that Palisades should initiate boric acid secondary water treatment to alleviate the denting process.
EVALUATION The NRC generally does not include secondary water chemistry limits or specific sampling locations and frequency in the Technical Specifications which are incorporated in the present Palisades Technical Specifications.
Most pressurized water reactors (PWRs) follow a program for monitoring of secondary water chemistry to inhibit steam generator corrosion which is specified in the administrative controls section of the Standard Technical Specifications.
By Generic Letter 85-02, issued April 17, 1985, the NRC issued NUREG-0844, "NRC Integrated Program for the Resolution of Unresolved Safety Issues A-3. A-4, and A-5 Regarding Steam Generator Tube Integrity."
i This publication gave the staff's recommendations with regard to secondary water chemistry, which is to have a secondary water chemistry program.
Specifically, the NRC staff's recommendations are stated as follows:
"Licensees and applicants should have a secondary water chemistry program (SWCP) to minimize steam generator tube degradation. The specific plant program should incorporate the secondary water chemistry guidelines in SG0G Special Report EPRI-NP-2704, "PWR Secondary Water Chemistry Guidelines," October 1982, and should address measures taken to minimize steam generator corrosion, including materials selection, chemistry limits, and control methods.
In addition, the specific plant procedures should include progressively more stringent corrective actions for out-of-specification water chemistry in2 %88s 818*&
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conditions. These corrective actions should include power reductions and shutdowns, as appropriate, when excessively corrosive conditions exist. Specific functional individuals should be identified as having the responsibility / authority to interpret plant water chemistry informa-tion and initiate appropriate plant actions to adjust chemistry, as necessary."
Revision 1 to "PWR Secondary Water Chemistry Guidelines" March 1987, EPRI NP-5056-SR, Appendix A, provides control parameter guidance for boric acid treatment as a remedial action for steam generator tube denting, which the NRC staff has endorsed.
The licensee proposed, and this amendment includes, the provisions of the Standard Technical Specifications for PWRs.
The licensee's application discusses how each of these requirements are met and provides the plant procedures which implement each of the required elements. We find that these procedures adequately implement the criteria for a secondary water chemistry program by incorporating the Standard Technical Specifications, and this change is therefore acceptable.
EXIGENT CIRCUMSTANCES The licensee requested that the NRC take prompt action on this change request in accordance with the provisions in 10 CFR 50.91(a)(6) for exigent circumstances.
The exigent circumstances result from the fact that the licensee has recently completed an inspection of the steam generators following a plant shutdown on December 4, 1987, because of a steam generator tube leak. The inspection results indicate a correlation between the crack in the tube and tube denting which occurs at the support plant-tube inter-face. To mitigate or stop the progression of tube denting, the licensee proposes a change in the chemistry control being used on the secondary side of the steam generator by the addition of boric acid.
This will not allow the licensee to meet the limits that were in place for the previous chemical treatment program. The plant is scheduled to go back on line on January 29, 1988. Specification 3.18 states that the chemistry limits must be met within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of going back on line. Therefore, an exigent change was needed.
The NRC staff has determined that the licensee used its best efforts to make a timely application under the circumstances, and that exigent circumstances do exist and were not the result of any fault of the licensee.
FINAL N0 SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION The Commission's regulations in 10 CFR 50.92 state that the Commission may make a final determination that a license amendment involves no significant hazards consideration if operation of the facility, in accordance with the amendment, would not:
(1) involve a significant increase in the probability or conse-quences of any accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or
(3) involve a significant reduction in a margin of safety.
The requested amendment has been evaluated against the standards in 10 CFR 50.92, and we have made a determination that the requested amendment involves no significant hazards considerations.
Water chemistry requirements do not establish minimum performance levels for plant safety and are adequately controlled as a plant procedure.
Thus, the change would not affect the probability of any accident previously evaluated.
In fact, the change to boric acid addition proposed by the licensee would be beneficial in mitigating steam generator degradation.
The changes in seco.1dary water chemistry do not affect the consequences cf any accident previously considered nor create the possibility of an accident of a different kind, nor decrease any margin of safety.
STATE CONSULTATION In accordance with the Commission's regulations, the designated' representative of the State of Michigan was contacted regarding this amendment. The State representative had no comments.
ENVIRONMENTAL CONSIDERATION This amendment involves a change in the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and a change in a surveillance requirement. We have detemined 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 increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public coment on such finding. Accordingly, this 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 or environmental assessment need be prepared in connection with the issuance of this amendment.
CONCLUSION We have 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, and (2) such activities will be conducted in compliance with the Comission's regulations, and the issuance of the amendment will not be inimical to the comon defense and security or to the health and safety of the public.
Date: February 1, 1988 Principal Contributor:
Thomas V. Wambach, NRR
i 8,
w Mr. Kenneth W. Berry
-Consumers Power Company Palisades Plant l
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I. Miller, Esquire Isham, Lincoln & Beale Nuclear Facilities and Sist Floor Environmental Monitoring Three First National Plaza Section Office Chicago, Illinois 60602 Division of Radiological Health Mr. Thomas A. McNish, Secretary P.O. Box 30035 Consumers Power Company Lansing, Michigan 48909 212 West Michigan Avenue Jackson, Michigan 49201 Judd L. Bacon, Esquire Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Regional Administrator, Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Jerry Sarno Township Supervisor Covert Township 36197 M-140 Highway Covert, Michigan 49043 Office of the Governor Room 1 - Capitol Building Lansing, Michigan 48913 Mr. David P. Hoffman Plant General Manager 1
Palisades Plant 1
27780 Blue Star Memorial Hwy.
Covert, Michigan 49043 Resident Inspector c/o U.S. Nuclear Regulatory Commission
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Palisades Plant i
27782 Blue Star Memorial Hwy.
Covert, Michigan 49043 9