ML20206J951

Safety Evaluation Supporting Amend 186 to License DPR-20

ML20206J951
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Site:	Palisades
Issue date:	05/06/1999
From:	NRC (Affiliation Not Assigned)
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NUDOCS 9905130027
Download: ML20206J951 (6)

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

't WASHINGTON D.C. 20066-0001

• • • • • ,o SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION i

RELATED TO AMENDMENT NO.186 TO FACILITY OPERATING LICENSE NO. DPR-20 CONSUMERS ENERGY COMPANY PAllSADES PLANT DOCKET NO. 50-255

1.0 INTRODUCTION

By letter dated September 3,1997, the Consumers Energy Company (the licensee) requested an amendment to the Technical Specifications (TS) appended to Facility Operating License No.

DPR-20 for the Palisades Plant. The proposed amendment would revise TS 3.14, Control Room Ventilation, to reflect the capabilities of the installed control room ventilation equipment and to emulate the requirements specified in NUREG-1432, " Standard Technical Specifications, Combustion Engineering Plants" (STS).

As proposed by the licensee in its submittals (December 19,1980, January 4,1982, and October 19,1982) in response to the NRC's Generic Letter 83-37 (GL), specifically, NUREG-0737, item Ill.D.3.4, relating to control room habitability requirements, the licensee replaced the original control room ventilation system with two redundant emergency air cleanup systems during the 1983/1984 refueling outage, The staff's safety evaluation dated April 29, 1983, had found the licensee's proposed modification of the control room ventilation system acceptable since it met the requirements of NUREG-0737, item Ill.D.3.4. Each of the two i

redundant systems consists of one air handling unit which can supply air up to 16,500 cubic feet per minute, one condensing unit to supply the required chilling capacity, and one HEPA (high efficiency particulate air filterycharcoal filter unit capable of supplying air to support the habitability requirements of the control room and the technical support center during an accident condition.

' By letter dated November 19,1984, and supplemented by letters dated November 21,1985, and February 28,1986, the licensee had requested an amendment to revise TS 3.14, to reflect the'capabiiities of the newly installed control room ventilation equipment. Subsequently, however, by letter dated January 24,1989, the licensee requested withdrawal of the

. November 19,1984, amendment request, and indicated that the proposed changes would be incorporated into the " Restructured (or improved) Technical Specifications" to be submitted at a later date.. in the interim, the licensee committed to implement and maintain the proposed changes under its administrative controls (i.e., Palisades Operating Requirements Manual).

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2-2.0 EVALUATION The proposed amendment includes the following changes:

I (a)..

TS Action Statement 3.14a is replaced by a revised condition description for TS Action Statement 3.17 *.6 in the instrumentation systems section. Also, the maximum control room temperature at which a shutdown must be initiated is revised from 120 'F to 90 'F, and a time limit for reaching the hot shutdown condition is specified.

l (b)

TS 3.14b is replaced with two limiting conditions for operation (LCOs),3.14.1 and j

3._14.2, addressing, respectively, the filtration and cooling functions of the CRHVAC i

[ control room heating, ventilation, and air conditioning] system. These proposed LCOs

. emulate the STS for control room ventilation.

l (c)

TS Table 4.2.3 surveillance requirement (SR) number 3, verificat5n of control room temperature, is moved to SR Table 4.17.1, for the reactor protection system (RPS), and

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(d) other administrative changes.

The licensee classified each change as either administrative or more restrictive. An administrative change is editorial in nature, only involves movement of requirements within the TS without affecting their technical content, or clarifies existing TS requirements. A more restrictive change adds new requirements, or revises existing requirements resulting in more conservative or additional operational restrictions.

2.1 Revision of TS 3.14a TS 3.14a currently 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.

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l TS 3.17.1.6 currently states:

If any action required by 3.17.1 is not met AND the associated completion time I

has expired, or if the number of OPERABLE channels is less than specified in the " Minimum OPERABLE Channels":

a) The reactor shall be placed in HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and I

b) The reactor shall be placed in a condition where the affected equipment is not required, within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

The licensee proposed to incorporate the requirements of TS 3.14a into TS 3.17.1.6, such that it reads:

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_ 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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and b) The reactor shall be placed in a condition where the t.ffected equipment is not required, within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

The licensee stated that the proposed change would reduce the maximum control room temperature at which a shutdown must be initiated from 120 'F to 90 'F. The purpose of this change is threefold: (1) the original equipment, including the RPS instrumentation, was designed and tested at 120 'F. The thermal margin monitor (TMM), which was added later, -

was designed for 131 *F, but control room temperature must be maintained at 90 'F or below to assure that the TMM cabinet internal air temperature does not exceed its design limit; (2) the corresponding surveillance requirement (TS Table 4.2.3, Ventilation System Test, item Number 3) was revised in Amendment Number 174 issued in October 31,1996, to read:

" Verifying that the Control Room temperature is less than or equal to 90 *F; once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />."

Thus, the proposed change to TS 3.14a and TS 3.17.1.6 would make the control room temperature limit consistent with TS Table 4.2.3; and (3) the proposed change satisfies a licensee commitment, as documented in a licensee letter dated December 7,1990, to incorporate the new temperature limit of 90 'F into the " Restructured (or Improved) Technical Specifications."

.The proposed change would also provide the appropriate action statement when the control room temperature is between 90 'F and 120 'F, since TS Table 4.2.3 does not provide any action statements and TS 3.14a does not require any action until the temperature reaches 120 'F. In addition, the proposed change would add a time limit for reaching Hot Shutdown when the maximum temperature is exceeded, rather than specifying that "immediate action shall be taken... to place the reactor in a hot shutdown condition," as currently stated in TS 3.14.a. The existing TS does not specify a time limit for completing the required action to place the plant in Hot Shutdown. The time limit proposed (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) is consistent with other existing TS action statements requiring the plant to be placed in Hot Shutdown. The alternate allowance of existing TS 3.14a to reduce control room temperature rather than shut down is

- provided by existing TS 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.' Therefore, this altemative need not be included in the revised TS.

In addition to retaining the provision of placing the plant in Hot Shutdown when the maximum-allowed control room temperature is exceeded, the proposed change would further specify that the reactor should be placed in a condition where the affected equipment is not required. This G

la more conservative and appropriate since, depending on plant conditions, the RPS and TMM may still be relied upon in Hot Shutdown to avoid unusual plant transients while the TMM could be considered inoperable as a result of high temperature in the control room.

By incorporating the requirements of TS 3.14a into TS 3.17.1.6, the proposed change would more closely relate the maximum allowed control room temperature and its associated action

4 with the TS requirements for the RPS, since the operability of TMM directly affects the operability of the RPS system.

The Bases for TS 3.17.1 would also be revised to include information regarding the additional requirement, i

The staff has determined that the proposed changes, as described above, constitutes more restrictive requirements that provide additional assurance that equipment conforms to the plant design basis and will operate reliably when called upon; therefore, the staff finds the proposed changes acceptable. '

2.2

. Revision of TS 3.14b The licensee proposed to replace TS 3.14b with two LCOs (and associated Actions),3.14.1 and 3.14.2. These proposed LCOs emulate the STS LCOs 3.7.11 and 3.7.12, for control room.

ventilation. The SRs for control room ventilation, with the exception of periodic verification of control room temperature as discussed in Section 2.3 of this safety evaluation, remain in Table 4.2.3.

The existing LCO (TS 3.14b) requires only one system, consisting of two fans and a filter system, reflecting the original design configuration for the purpose of control room ventilation.

Proposed TS 3.14.1 requires 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 of activated charcoal adsorbers for removal of gaseous activity (principally iodine), a second HEPA filter, and a fan. In addition, proposed TS 3.14.2 requires two redundant cooling trains, each consisting of heating coils, cooling coils, instrumentation, and controls to provide for control room temperature control. The proposed changes reflect the capabilities of the modified control room ventilation equipment and also emulate the requirements specified in STS for control room ventilation.

The current TS 3.14b has no explicit applicability; existing Actions imply the applicability is "above Cold Shutdown." The proposed TS 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.

Existing actions allow both fans (i.e., 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 <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (i.e.,

a total allowed outage time (AOT) of less than 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />). The required actions in each proposed TS (TS 3.14.1 and TS 3.14.2) require immediate entry into TS 3.0.3, consistent with the STS.(i.e., total AOT of less than 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />), for both trains being inoperable during operation above Cold Shutdown.

In addition, required Actions emulating those in the STS are provided in each proposed TS (TS 3.14.1 and TS 3.14.2) for conditions where (1) one required train is inoperable, and (2) two trains are inoperable during Cold Shutdown or under other applicable conditions.

- The Basis for TS 3.14.1 and TS 3.14.2 would be appended to include information regarding the proposed changes.

-The proposed changes provide requirements that are either new, or more conservative than existing TS requirements. These changes represent additional restrictions on plant operation that enhance safety and are consistent with the STS. Therefore, the staff finds the proposed changes, as described above, acceptable.

2.3 Administrative Chanaes The licensee proposed to move TS Table 4.2.3 SR number 3, verification of control room temperature, to the RPS SR Table 4.17.1. The remaining SRs in Table 4.2.3 are not affected.

This change does not alter any TS requirements and was therefore classified as administrative by the licensee.

The licensee also proposed to revise Table of Contents page li to show the proposed new sections of TS 3.14. This change does not alter any TS requirements and was classified as administrative by the licensee, in addition, the licensee proposed to delete the " Applicability' and " Objective" paragraphs of the existing TS 3.14 and place equivalent information in the Bases sections. The licensee stated

. that these sections do not contain any operating limitations or restrictions; they provide only background information and would be replaced with extensivo bases discussions. This change does not alter any TS requirements and was therefore classified as administrative by the licensee.

These changes are editorial in nature or involve the reorganization or reformatting of TS -

requirements without affecting technical content or operational restrictions. The proposed changes do not result in any substantive change in operating requirements or the intent of these requirements, and are consistent with the Commission's regulations; therefore, the staff finds the proposed changes 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 component 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 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 (64 FR 14281). 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),

6-no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

5.0 CONCLUSION

The Commission 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 defense and security or to the health and safety of the public.

Principal Contributors: T. Kim R. Schaaf Date: 'May 6, 1999 l

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