ML20207F261
| ML20207F261 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/22/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20207F249 | List: |
| References | |
| GL-91-08, GL-91-8, NUDOCS 9903110207 | |
| Download: ML20207F261 (5) | |
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1-UNITED STATES g
t NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. SteeMoM l
SAFETY EVALUATION BY THE OFFICE OF NUCl. EAR REACTOR REGULATION.
RELATED TO_ AMENDMENT NO.184TO FACILITY OPERATING LICENSE NO. DPR-20 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET NO,50-255
1.0 INTRODUCTION
By letter dated March 26,1997, the Consumers Energy Company (the licensee) requested an amendment to the Technical Specifications (TS) appended to Facility Operating License No.
i DPR 20 for the Palisades Plant. The amendment would modify TS sections 3.6 and 4.5 by removing the list of containment isolation valves in accordance with Generic Letter (GL) 91-08,
" Removal of Component Lists from Technical Specifications," dated May 6,1991 and by revising requirements related to containment pressure and containment temperature.
Additionally, several editorial changes were proposed to emulate the format and content of NUREG 1432, " Standard Technical Specifications, Combustion Engineering Plants," (STS).
One of the requested provisions would incorporate a note to allow opening an operable airlock door to perform repairs on inoperable airlock components when the other airlock door is inoperable. This provision was reviewed and approved in Amendment No.179 issued on April 8,1998. The remainder of the licensee's proposed changes are evaluated below.'
2.9 EVALUATION Deletion of Table 3.8.1' In its submittal, the licensee proposed deleting Table 3.6.1," Containment Penetrations and Valves," from TS 3.6.1, in accordance with the guidance of GL 91-08. The current table lists
.. containment penetrations, their functions, the isolation valve number, and the required closure time.J The table also included an allowance to open the manual valves on penetration 33, the safety injection tank drain line, for sampling. GL 91-08 provides guidance on revising the wording of the TS to incorporate the deletion of lists of containment isolation valves. The licensee followed the guidance in GL 91-08 as applicable to the plant and has proposed the following TS changes.
l-Table 3.6.1 would be deleted.
i References to Table 3.6.1 would be removed from the TS Table of Contents and from l:
the definition of containment integrity.
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. Surveiilance Requhement (SR) 4.5.3.c would be revised to delete the reference to Table 3.6.1. The proposed revision to SR 4.5.3.c, Isolation Valve Timing, omits specifying valve closure time, but requires valve timing to be verified in accordance with Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code. The inservice testing required by TS 6.5.7, the inservice inspection and Testing Program, includes the verification of stroke ti_mes for a broader class of valves than those listed in Table 3.6.1. The removal of va!ve closure times from this SR does not alter the TS requirement to. verify that the valve stroke times are within their limits.
A footnote would be added to Limiting Condition for Operation (LCO) 3.6.1 to address opening isolation valves under administrative controls. The proposed wording for the -
footnote and for the basis explanation of the note were in accordance with the guidance of GL 91-08. Reference to this footnote would also be added to current TS 3.6.3 (which i
will be renumbered SR 4.5.3d as discussed under Administrative Changes below).
The staff has reviewed the licenste's proposed deletion of Table 3.6.1 and its associated TS changes and determined that the changes are in accordance with the guidance of GL 91-08.
Deleting the list of containment isolation valves does not alter the existing TS requirements or the components they apply to. Lists of containment isolation valves are provided in the Final Safety Analysis Report and in the plant procedures for performing penetration leak testing and isolation valve closure time testing. The set of valves subject to the requirements of TS 3.6 and 4.5 will not change due to the proposed change. The staff, therefore, finds the proposed changes acceptable.
Containment Pressure The licensee also proposed changes to TS 3.6.2 regarding containment pressure. The current TS requires containment pressure to be maintained below 3 psig. This TS limit has not been j
changed since the initial Palisades TS were issued in 1971. However, since that time the accident analyses, for at-power conditions, have been revised to use a more restrictive llmit of 1.0 psig. The 1.0 psig limit has been maintained by administrative controls.
Because the containment purge valves must remain closed, containment air temperature and pressure tend to rise as the plant is heated to operating temperature. The licensee stated that, due to the low allowable pressure and limited containment ventilation path, this pressure rise has occasionally restricted the heatup rate and unnecessarily delayed returning the plant to service. The licensee performed a special containment analysis that is applicable only with the reactor shutdown. The analysis demonstrated that containment design pressure and tempuature would not be exceeded for a loss-of-coolant accident (LOCA) or a main steam line break (MSLB) with an initial containment pressure of 1.5 psig, provided the reactor was subcritical.
The licensee has proposed revising LCO 3.6.2 to provide two containment pressure limits. A limit of 1.5 psig, to be applicable when the plant is above Cold Shutdown (i.e., when the primary i
coolant system (PCS) is above 210 'F); and a limit of 1.0 psig, to be applicable when the plant Is in Power Operation or Hot Standby (i.e., when the reactor may be critical). The proposed LCO does not apply when the plant is in Cold Shutdown (i.e., below 210 'F). The containment pressure LCO is not necessary during Cold Shutdown because it is intended to assure that I
3-design containment pressure is not exceeded if a LOCA or MSLB should occur. With the plant at Cold Shutdown, neither the PCS nor the main steam system contains sufficient energy to cause containment pressurization if a piping failure should occur.
in addition, the licensee has proposed adding an action statement to TS 3.6.2 to provide guidance on action to be taken if containment pressure exceeds the specified limit. The proposed action statement requires restoring containment pressure to within the limit within i
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in at least Hot Shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Cold Shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
- The staff has reviewed the licensee's proposed changes to TS 3.6.2. Since the revised limits i
are both more restrictive than the current TS limit, and the applicability and action statements I
are consistent with the STS, the staff finds the proposed changes acceptable.
I
- Containment Air Temoerature The licensee proposed adding a new LCO to provide a TS limit on containment average air i
temperature. The new LCO would replace LCO 3.6.3 which would be renumbered as SR 4.5.3d (this renumbering is discussed as an administrative change below). The current TS contain no limit on containment air temperature, yet the value is used as an initial condition of
- the safety analyses and therefore meets Criterion B of 10 CFR 50.36(c)(2)(ii). The proposed i
. limit is the value used in the safety analyses and the proposed Action is modeled after the STS.
~ The basis discussion on containment pressure would also be expanded to discuss containment temperature.
The licensee's proposed addition of a containment air temperature LCO meets the criteria of 10 CFR 50.36 and is consistent with the STS. The staff, therefore, finds the proposed change acceptable.
Administrative Chances in addition to the changes discussed above, the licensee has proposed several administrative changes to enhance the clarity of these TS sections by grouping the LCOs together, by deleting
-unnecessary wording, and by using consistent terminology throughout. These changes are summarized below.
Throughout TS Sections 3.6 and 4.5, terms defined in TS Section 1.0, " Definitions,"
would be replaced with uppe case text to indicate that the term is a defined term.
The definition of containment integrity would be revised by deleting the phrase,"when all the following are true," since it is implied that the listed conditions must be true. The word " personnel" would be deleted from the definition to assure the requirement is understood to apply to both the Personnel and Emergency Escape air locks. In addition the parenthetical reference to the TS 4.5.2 SR to amplify " operable" would be deleted since it is redundant with the TS 4.0.3 requirement that SRs be performed within their specified intervals in order for a component to be considered operable.
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. 1 TS Section 3.6 would be restructured by deleting the " applicability" and " objective" statements since they contain no requirements. The LCO section would be learranged to put all LCOs on one page and the bases on the following page.~ A basis paragraph
' for hydrogen recombiners would be added where none previously existed.
In LCO 3.6.1, the wording " Containment Integrity shall not be violated," would be replaced with " Containment integrity shall be maintained." The statement, "as defined in Specification 1.0," would be deleted since that information would now be provided by upper case text for definitions as proposed above.
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LCO 3.6.1a would be revised to state the LCO applicability as "when the plant is above
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COLD SHUTDOWN" rather than to state that it "shall not be violated unless the reactor j
is in the cold shutdown condition." The revised wording will provide a more direct i
statement of the requirement and its applicable conditions by stating when containment i
integrity must be met rather than when it may be violated. LCOs 3.6.1b and 3.6.1c j
would be reviseu similarly and editorially reworded for clarity.
LCO Actions 3.6.1b and 3.6.1c would be combined and revised to use wording similar to the STS. Action 3.6.1d would be renumbered 3.6.1c.
Current LCO 3.6.3 is actually an SR so it is proposed to be moved to Section 4 as SR 4.5.3d. The requirement would also be revised to require a " visual" check rather than an
" administrative" check. The licensee stated that thia is considered to be a clarification since the basis describes the required check as visual and the requirement has always been performed by visually checking each valve. The basis paragraph would also be moved to Section 4.5.
LCO 3.6.4 and the included Action would be rewritten to use more consistent terminology for the hydrogen recombiners.
LCO 3.6.5 would be rewritten. The title would be deleted and parts a. and b. would be combined similar to the proposed revisions to other LCOs in Section 3.6. The applicable conditions would be made more restrictive in order to agree with the LCO for containment integrity. The component identifiers for the purge exhaust and air room supply isolation valves would be deleted. A revision would be made to address the subject valves as not being locked closed rather than addressing them being open and the specific requirement to "electricaUy" lock the valves would be removed since it
' implied that other means of locking the valves were unacceptable.
Section 4.5 would be revised for consistency and clarification purposes. Numbers written in the form "s!x (6)" would be revised to eliminate the redundancy. The second paragraph of action statement 4.5.2c(3) would be renumbered as its own paragraph (4) since it addresses a different condition and provides different required actions then the first paragraph of c(3). Paragraph 4.5.2d(1) would be revised to delete a frequency requirement referring to the period prior to the first post-operational integrated leak rate testing, which is no longer applicable.
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5-SR 4.5.2d(2) would be moved from Section 4.5.2 to Section 4.5.3 and renumbered 4.5.3e, since the subject paragraph deals with containment isolation valve testing (the
- subject of 4.5.3) and not the frequency of local leak rate testing (the subject of 4.5.2).
SR.4.5.3a would be revised to change the wording, " prior to returning the valve to service," with " prior to declaring the valve to be operable." This change is intended to avoid the implication that the valve cannot be returned to service during periods when containment integrity (and isolation valve operability) is not required without performance of the required testing.
The proposed administrative changes provide clarification and consistency within the TS i
without affecting their technical content. The staff, therefore, 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 requirements 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 (62 FR 66136). 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 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 activit' will be conducted in compliance with the Commission's regulations, and (3) the issuance.-
e amendment will not be inimical to the common defense and security or to the health (
.fety of the public.
Principal Contributor: R. Laufer Date: _ February 22, 1999
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