|
|
(4 intermediate revisions by the same user not shown) |
Line 3: |
Line 3: |
| | issue date = 04/07/1994 | | | issue date = 04/07/1994 |
| | title = Application for Amend to License DPR-20,requesting TS Change Re Instrumentation & Control Section | | | title = Application for Amend to License DPR-20,requesting TS Change Re Instrumentation & Control Section |
| | author name = ROGERS D W | | | author name = Rogers D |
| | author affiliation = CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), | | | author affiliation = CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), |
| | addressee name = | | | addressee name = |
Line 14: |
Line 14: |
| | document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS & PERMITS | | | document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS & PERMITS |
| | page count = 2 | | | page count = 2 |
| | | project = |
| | | stage = Request |
| }} | | }} |
|
| |
|
| =Text= | | =Text= |
| {{#Wiki_filter:consumers Power David W. Rogers Plant Safety and Licensing Director POWERINli PRDliRESS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 April 7, 1994 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 -LICENSE DPR-20 -PALISADES PLANT -TECHNICAL SPECIFICATIONS CHANGE REQUEST -INSTRUMENTATION AND CONTROL -ADDITIONAL HAZARDS ANALYSIS. | | {{#Wiki_filter:consumers Power David W. Rogers Plant Safety and Licensing Director POWERINli MICHlliAN~S PRDliRESS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 April 7, 1994 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - TECHNICAL SPECIFICATIONS CHANGE REQUEST - INSTRUMENTATION AND CONTROL - ADDITIONAL HAZARDS ANALYSIS. |
| On November 15 1991, Consumers Power Company (CPCo) submitted a Technical Specifications (TS) change request which proposed completely rewritten requirements for the Instrument and Control (I&C) sections of the Palisades TS. This change request contained a No Significant Hazards (NSH) analysis which addressed the proposed changes. On February 22 and March 11, 1994, CPCo submitted revisions and additions to the November 15, 1991 submittal, concluding in each case that the revisions did not alter the conclusions of the original NSH analysis. | | On November 15 1991, Consumers Power Company (CPCo) submitted a Technical Specifications (TS) change request which proposed completely rewritten requirements for the Instrument and Control (I&C) sections of the Palisades TS. |
| It has come to our attention that the NSH analysis submitted on November 15, 1991 does not address all of the additions to that submittal which were subsequently proposed. | | This change request contained a No Significant Hazards (NSH) analysis which addressed the proposed changes. On February 22 and March 11, 1994, CPCo submitted revisions and additions to the November 15, 1991 submittal, concluding in each case that the revisions did not alter the conclusions of the original NSH analysis. |
| This letter provides a general discussion of the proposed revisions and additions proposed in our February 22 and march 11, 1994 submittals. | | It has come to our attention that the NSH analysis submitted on November 15, 1991 does not address all of the additions to that submittal which were subsequently proposed. This letter provides a general discussion of the proposed revisions and additions proposed in our February 22 and march 11, 1994 submittals. A NSH analysis, addressing those items not discussed in the 1991 submittal NSH analysis, is provided as Attachment 1. |
| A NSH analysis, addressing those items not discussed in the 1991 submittal NSH analysis, is provided as Attachment | | The revisions and additions proposed to the 1991 submittal are as follows: |
| : 1. The revisions and additions proposed to the 1991 submittal are as follows: 1) Changes to the affected pages made by intervening amendments, 2) Clarifications suggested by NRC and Palisades reviewers, 3) Addition of two instrument channels to the "Accident Monitoring Instruments" (AMI) Limiting Condition for Operation (LCO), 4) Deletion of surveillance requirements for Safety Injection Tank (SIT) instruments, as suggested by Generic Letter (GL) 93-05, and 5) Addition of a general "Applicability" LCO which appears in the Standard Technical Specifications (STS) but not in the Palisades TS. -------------*-1:T4o415ois3 940407 ADOCK A CMS' ENERGY COMPANY Item 1 merely updates the submittal to reflect the current operating license, and need no further justification.
| | : 1) Changes to the affected pages made by intervening amendments, |
| Item 2 simply enhances clarity and does not change any operating limits or requirements, or any conclusions of the NSH analysis submitted in 1991. Item 3 is addressed by the NSH analysis submitted in 1991; that analysis addressed the addition of the entire AMI LCO. The two channels in question, steam generator narrow-range level instruments, were omitted from the AMI LCO of the 1991 submittal because they are required by the proposed (and existing) | | : 2) Clarifications suggested by NRC and Palisades reviewers, |
| | : 3) Addition of two instrument channels to the "Accident Monitoring Instruments" (AMI) Limiting Condition for Operation (LCO), |
| | : 4) Deletion of surveillance requirements for Safety Injection Tank (SIT) instruments, as suggested by Generic Letter (GL) 93-05, and |
| | : 5) Addition of a general "Applicability" LCO which appears in the Standard Technical Specifications (STS) but not in the Palisades TS. |
| | ~\ |
| | -----*-1:T4o415ois3 940407 |
| | ~DR ADOCK Q500~5~5 A CMS' ENERGY COMPANY |
| | |
| | Item 1 merely updates the submittal to reflect the current operating license, and need no further justification. |
| | Item 2 simply enhances clarity and does not change any operating limits or requirements, or any conclusions of the NSH analysis submitted in 1991. |
| | Item 3 is addressed by the NSH analysis submitted in 1991; that analysis addressed the addition of the entire AMI LCO. The two channels in question, steam generator narrow-range level instruments, were omitted from the AMI LCO of the 1991 submittal because they are required by the proposed (and existing) |
| Reactor Protective System (RPS) LCO. Subsequently, it was noted that the applicability of the RPS LCO was not the same as for the AMI LCO, therefore, the instrument channels were added to the AMI LCO and surveillance. | | Reactor Protective System (RPS) LCO. Subsequently, it was noted that the applicability of the RPS LCO was not the same as for the AMI LCO, therefore, the instrument channels were added to the AMI LCO and surveillance. |
| Item 4, deletion of requirements for the Safety Injection Tank instrument surveillance (as suggested in GL 93-05), is discussed in the NSH analysis provided in Attachment | | Item 4, deletion of requirements for the Safety Injection Tank instrument surveillance (as suggested in GL 93-05), is discussed in the NSH analysis provided in Attachment 1. Existing Palisades TS contain 3 surveillance requirements associated with the SIT instrument channels as items 13a, b, and c of Table 4.1.2. These are requirements for verification that SIT level and pressure are within limits, a instrument channel check, and an instrument channel calibration. Table 4.1.2 has been replaced with proposed Table 4.17.6. |
| : 1. Existing Palisades TS contain 3 surveillance requirements associated with the SIT instrument channels as items 13a, b, and c of Table 4.1.2. These are requirements for verification that SIT level and pressure are within limits, a instrument channel check, and an instrument channel calibration.
| | Those items in existing Table 4.1.2 which are not related to instrument channel operability, such as verification of SIT level and pressure, have been moved to more appropriate sections of the TS. As proposed, the verification of SIT level and pressure appears, essentially unchanged, as item 10 of Table 4.2.2. The SIT instrument channel surveillance requirements have been deleted as suggested by GL 93-05. |
| Table 4.1.2 has been replaced with proposed Table 4.17.6. Those items in existing Table 4.1.2 which are not related to instrument channel operability, such as verification of SIT level and pressure, have been moved to more appropriate sections of the TS. As proposed, the verification of SIT level and pressure appears, essentially unchanged, as item 10 of Table 4.2.2. The SIT instrument channel surveillance requirements have been deleted as suggested by GL 93-05. Item 5, addition of LCO 3.0.5 from the STS (NUREG 1432), is also addressed in the NSH analysis provided in Attachment | | Item 5, addition of LCO 3.0.5 from the STS (NUREG 1432), is also addressed in the NSH analysis provided in Attachment 1. One of the operational changes proposed for the I&C TS requires that an inoperable RPS channel be placed in the "TRIP" condition, eliminating the option for operation with a channel continuously bypassed. At Palisades, an RPS channel is placed in TRIP by actually de-energizing the trip unit module. The requirement to place a channel in TRIP, therefore, eliminates the possibility of post maintenance testing since such testing cannot be accomplished with the channel tripped (de-energized). This conflict was recognized during the writing of the new STS, NUREG 1432 etc; the subject LCO 3.0.5 was introduced as the result. That LCO would allow an inoperable channel, which had been placed in TRIP, to be repaired, tested, and returned to service. At the time the 1991 submittal was being prepared, NUREG 1432 had not been published. |
| : 1. One of the operational changes proposed for the I&C TS requires that an inoperable RPS channel be placed in the "TRIP" condition, eliminating the option for operation with a channel continuously bypassed.
| | A copy of thi~ letter has been sent to the State of Michigan. |
| At Palisades, an RPS channel is placed in TRIP by actually de-energizing the trip unit module. The requirement to place a channel in TRIP, therefore, eliminates the possibility of post maintenance testing since such testing cannot be accomplished with the channel tripped (de-energized). | | ~CJ.~ |
| This conflict was recognized during the writing of the new STS, NUREG 1432 etc; the subject LCO 3.0.5 was introduced as the result. That LCO would allow an inoperable channel, which had been placed in TRIP, to be repaired, tested, and returned to service. At the time the 1991 submittal was being prepared, NUREG 1432 had not been published. | |
| A copy of letter has been sent to the State of Michigan. | |
| David W. Rogers Plant Safety and Licensing Director CC Administrator, Region III, USNRC Resident Inspector, Palisades Attachment}} | | David W. Rogers Plant Safety and Licensing Director CC Administrator, Region III, USNRC Resident Inspector, Palisades Attachment}} |
|
---|
Category:OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING
MONTHYEARML18066A3251998-11-0909 November 1998 Application for Amend to License DPR-20,deleting CVCS Operability Requirements Currently in LCOs 3.2 & 3.17.6 & Associated Testing Requirements in SRs 4.2 & 4.17 ML18066A1981998-06-17017 June 1998 Application for Amend to License DPR-20,updating TS to Reflect Reduced Min Reactor Vessel Flow Rate Assumption in Accident Analyses ML18065B1831998-03-13013 March 1998 Revised Application for Amend to License DPR-20,requesting Relocation of TS Section 4.16 Snubber Testing Requirements to Plant Operating Requirements Manual (Orm).Affected Orm Pages Encl ML18065B1781998-03-13013 March 1998 Application for Amend to License DPR-20,changing Auxiliary Feedwater TS to Allow Installation of Plant Mod W/O Requiring Plant Shutdown ML18067A7051997-10-0101 October 1997 Application for Amend to License DPR-20,proposing That TS Flywheel Insp Period Be Lengthened to Ten Years & Deleting Note Re Insp at End of Cycle 12 ML18067A6751997-09-0303 September 1997 Application for Amend to License DPR-20,deleting Snubber Operability Requirements in LCO 3.20 & Snubber Testing Requirements in Surveillance Requirement 4.16 ML18067A6711997-09-0303 September 1997 Application for Amend to License DPR-20,reflecting Capabilities of Installed CR Ventilation Equipment & Emulate Std Tech Specs,C-E Plants,Per NUREG-1432 Requirements for Sys ML18067A4511997-03-26026 March 1997 Application for Amend to License DPR-20,allowing Entry Into Air Lock to Perform Repairs on Inoperable Air Lock Door & Thereby Avoid Potential for Unnecessary Plant Shutdown ML18065A4891996-02-0606 February 1996 Application for Amend to License DPR-20,requesting to Remove cross-train Testing Requirements from LCO Action Statements ML18065A4381996-01-18018 January 1996 Application for Amend to License DPR-20,revising TS to Allow Use of 10CFR50 App J Option B Containment Testing & Use of Warning Light to Identify Certain High Radiation Areas,To Suppl 951211 Administrative Controls Change Request ML18065A4341996-01-18018 January 1996 Application for Amend to License DPR-20,revising TS Re Primary Coolant Pump Flywheel Insp.Rev 1 to Structural Integrity Assoc,Inc Rept SIR-94-080, Relaxation of Reactor Coolant Pump Flywheel Insp Requirements Encl ML18065A4051996-01-10010 January 1996 Application for Amend to License DPR-20,requesting Exemption from 10CFR50 App J TS Change Request Concerning Local Leak Test Requirements for Emergency Escape Airlock in Plant Containment Bldg ML18065A3821996-01-0505 January 1996 Application for Amend to License DPR-20,revising SDC Requirements & Bases for TS Section 3.1.9.3 Prior to 1996 Refueling Outage ML18065A3751995-12-27027 December 1995 Application for Amend to License DPR-20,rewriting Electrical Power Sys Sections of TS & Bases to Closely Emulate STS ML18065A3461995-12-11011 December 1995 Application for Amend to License DPR-20,revising Administrative Controls Section to Emulate CE STS by Removing Review & Audit Requirements of Section 6.5 & Record Retention Requirements of Section 6.10 from TS ML18065A3321995-12-0606 December 1995 Application for Amend to License DPR-20,relocating Crane Operation & Movement of Heavy Loads Requirements & Bases from TS to Other Plant Documents Prior to 1996 Refueling Outage ML18065A1741995-10-17017 October 1995 Application for Amend to License DPR-20,changing Paragraph 2.B.(2) to Ref 10CFR40 & to Allow Use of Source Matls as Reactor Fuel,Rewording Paragraph 2.E & Deleting Paragraph 2.7 & Revising TS Pressurizer Cooldown Limit ML18064A8391995-07-0505 July 1995 Application for Amend to License DPR-20,deleting TS 6.4, Training & Revising TS 6.5.1.2 on Plant Review Committee Composition & 6.5.3.1 & 6.5.3.2,clarifying & Modifying Function & Composition of Plant Safety & Licensing Staff ML18064A7591995-05-0101 May 1995 Application for Amend to License DPR-20.Amend Would Place Requirements in TS Section 4.7 for Periodic DG Peak Load Tests ML18064A6121995-02-10010 February 1995 Application for Amend to License DPR-20,proposing One Time Deferral of 18-month Refueling Interval Surveillance Tests ML18064A5821995-01-13013 January 1995 Tech Specs Change Request to License DPR-20 Addressing Required Settings & Allowable as Found & as Left Tolerances for Primary & Secondary Safety Valves ML18064A5341994-12-29029 December 1994 Application for Amend to License DPR-20,revising TSs Re Iodine Removal Sys ML18064A5061994-12-13013 December 1994 Application for Amend to License DPR-20,adding Third High Thermal Performance DNB Correlation to Safety Limit 2.1 ML18064A4081994-10-0505 October 1994 Application for Amend to License DPR-20,revising TS Relating to Primary Coolant Sys pressure-temp Limits.Rev 0 to Engineering Analysis EA-A-PAL-92-095-01 & Excerpts from Rosemount Instruction Manual 4515,dtd Jan 1988 Encl ML18059B0961994-07-0707 July 1994 Application for Amend to License DPR-20,revising TS Re Shutdown Cooling.Changes Intended to Resolve Concerns Arose During NRC Review of Change Request ML18059A9751994-05-0505 May 1994 Application for Amend to License DPR-20,revising TS Re Shutdown Cooling.Changes Necessary Due to Intervening Amends Containing Listed Differences from Pages Submitted on 930519 ML18059A9321994-04-0707 April 1994 Application for Amend to License DPR-20,requesting TS Change Re Instrumentation & Control Section ML18059A9411994-04-0707 April 1994 Application for Amend to License DPR-20,relocating Cycle Specific Operating Limits to Colr,Per Guidance of GL 88-16, Removal of Cycle-Specific Parameter Limits from Ts. Proposed COLR Encl ML18059A8851994-03-11011 March 1994 Rev to 940222 I&C TS Change Request to License DPR-20,adding Surveillance Item 10 to Table 4.2.1 Which Require Verifying SIT Level & Pressure Each Shift & Adding Three Paragraphs to Basis for Proposed Section 3.17 ML18059A3721993-09-0303 September 1993 Changes to 930129 Application for Amend to License DPR-20, Modifying Radial Peaking Factor Limits in TS Table 3.23-2 to Incorporate Appropriate Limits for Modified L Fuel Assemblies Recently Installed in Reactor for Cycle 11 ML18058B8991993-06-25025 June 1993 Revises 921208 Application for Amend to License DPR-20 & Brings Proposed Specifications Closer to Model Tech Specs, While Retaining Necessary plant-specific Differences & Updating Proposed Pages to Reflect Amends 147 & 149 ML18058B7421993-03-29029 March 1993 Application for Amend to License DPR-20,changing TS to Required Frequency for Surveillance Test Which Requires Moving Each Control Rod to Once Each 92 Days Instead of Once Every 2 Wks ML18058B3881993-01-29029 January 1993 Application for Amend to License DPR-20,consisting of Proposed TS Changes to Table 3.23-2, Radiation Peaking Factor Limits for Cycle 11. Offsite Dose Calculations & EMF-92-178, Palisades Cycle 11:Disposition & ... Encl ML18058B3481993-01-19019 January 1993 Application for Amend to License DPR-20,changing Surveillance Interval for Testing Control Rod Drive mechanisms,CRD-20 & CRD-31 from Every Two Wks to Once in Mar 1993 ML18058A5631992-06-22022 June 1992 Suppl to 920317 Application for Amend to License DPR-20, Consisting of Revised Page 3-82 Re Shutdown Cooling ML18058A5561992-06-12012 June 1992 Application for Amend to License DPR-20,changing TS to Better Coordinate Required Action Statement of Electrical Sys Spec W/Lco to Allow Testing & Loading of DG When Plant Above 325 F But Not Yet Critical ML18058A5491992-06-12012 June 1992 Application for Amend to License DPR-20,changing TS to Delete Requirements Re Iodine Removal Sys Hydrazine Storage Tank Since Use of Hydrazine No Longer Considered in Current Rev of SRP ML18058A3631992-04-15015 April 1992 Application for Amend to License DPR-20,changing TSs to Incorporate Generic Ltr 90-06 PORV Requirements for Power Operation & Modifying Pcs Overpressure Protection Spec Venting Requirements ML18058A2921992-03-18018 March 1992 Application for Amend to License DPR-20,revising TS Re Shutdown Cooling ML18058A1541992-02-0303 February 1992 Application for Amend to License DPR-20,deleting Three Primary Coolant Pump Testing Requirements & Revising Safety Limits & Limiting Safety Sys Settings Specs to Enhance Clarity of Subj Requirements ML18057B3711991-11-12012 November 1991 Application for Amend to License DPR-20,revising Tech Specs to Remove Schedule for Withdrawal of Reactor Vessel Matl Specimens,Per Generic Ltr 91-01 ML18057B3481991-11-0101 November 1991 Application for Amend to License DPR-20,changing TS for Operation During Cycle 10 as Results of Changes to Fuel Design (Reload N) & Fuel Mgt Scheme for Low Leakage Core. Siemens Repts EMF-91-176 & EMF-91-177 Encl ML18057B3061991-09-27027 September 1991 Application for Amend to License DPR-20,proposing Change to Tech Spec 5.2.3.a Re Containment Air Cooler Design,Per 861020 & 870430 Requests ML18057B3021991-09-26026 September 1991 Application for Amend to License DPR-20,consisting of Rev 2 to 890628 Request,In Response to Recommendations of Generic Ltr 88-17 to Add Shutdown Cooling Sys Operability Requirements to Tech Specs ML18057B1681991-07-15015 July 1991 Application for Amend to License DPR-20,requesting Tech Spec Changes in Administrative Controls W/Emphasis on Changes in Engineering ML18057A9821991-06-13013 June 1991 Application for Amend to License DPR-20,revising Tech Specs to Incorporate Change to Inservice Insp Program for Shock Suppressors (Snubbers) ML18057A9631991-05-30030 May 1991 Application for Amend to License DPR-20,changing Tech Specs to Incorporate Change to Reactor Variable High Power Trip setpoint.ANF-90-181, Review & Analysis of SRP Chapter 15 Events for Palisades W/15% Variable High Power... Encl ML18057A9551991-05-28028 May 1991 Application for Amend to License DPR-20,changing Tech Specs Re Inservice Insp Program for Shock Suppressors (Snubbers) ML18057A8881991-05-0101 May 1991 Rev 1 to Application for Amend to License DPR-20,changing TS Re Shutdown Cooling Sys Per Generic Ltr 88-17,by Adding Operability Requirements for Shutdown Cooling Sys & Steam Generators ML18057A8291991-03-25025 March 1991 Application for Amend to License DPR-20,changing Tech Specs Section 4.5.2a(2) & 4.5.2b(3) 1998-06-17
[Table view] Category:TEXT-LICENSE APPLICATIONS & PERMITS
MONTHYEARML18066A3251998-11-0909 November 1998 Application for Amend to License DPR-20,deleting CVCS Operability Requirements Currently in LCOs 3.2 & 3.17.6 & Associated Testing Requirements in SRs 4.2 & 4.17 ML18066A1981998-06-17017 June 1998 Application for Amend to License DPR-20,updating TS to Reflect Reduced Min Reactor Vessel Flow Rate Assumption in Accident Analyses ML18065B1831998-03-13013 March 1998 Revised Application for Amend to License DPR-20,requesting Relocation of TS Section 4.16 Snubber Testing Requirements to Plant Operating Requirements Manual (Orm).Affected Orm Pages Encl ML18065B1781998-03-13013 March 1998 Application for Amend to License DPR-20,changing Auxiliary Feedwater TS to Allow Installation of Plant Mod W/O Requiring Plant Shutdown ML18067A7051997-10-0101 October 1997 Application for Amend to License DPR-20,proposing That TS Flywheel Insp Period Be Lengthened to Ten Years & Deleting Note Re Insp at End of Cycle 12 ML18067A6751997-09-0303 September 1997 Application for Amend to License DPR-20,deleting Snubber Operability Requirements in LCO 3.20 & Snubber Testing Requirements in Surveillance Requirement 4.16 ML18067A6711997-09-0303 September 1997 Application for Amend to License DPR-20,reflecting Capabilities of Installed CR Ventilation Equipment & Emulate Std Tech Specs,C-E Plants,Per NUREG-1432 Requirements for Sys ML18067A4511997-03-26026 March 1997 Application for Amend to License DPR-20,allowing Entry Into Air Lock to Perform Repairs on Inoperable Air Lock Door & Thereby Avoid Potential for Unnecessary Plant Shutdown ML18065A4891996-02-0606 February 1996 Application for Amend to License DPR-20,requesting to Remove cross-train Testing Requirements from LCO Action Statements ML18065A4381996-01-18018 January 1996 Application for Amend to License DPR-20,revising TS to Allow Use of 10CFR50 App J Option B Containment Testing & Use of Warning Light to Identify Certain High Radiation Areas,To Suppl 951211 Administrative Controls Change Request ML18065A4341996-01-18018 January 1996 Application for Amend to License DPR-20,revising TS Re Primary Coolant Pump Flywheel Insp.Rev 1 to Structural Integrity Assoc,Inc Rept SIR-94-080, Relaxation of Reactor Coolant Pump Flywheel Insp Requirements Encl ML18065A4051996-01-10010 January 1996 Application for Amend to License DPR-20,requesting Exemption from 10CFR50 App J TS Change Request Concerning Local Leak Test Requirements for Emergency Escape Airlock in Plant Containment Bldg ML18065A3821996-01-0505 January 1996 Application for Amend to License DPR-20,revising SDC Requirements & Bases for TS Section 3.1.9.3 Prior to 1996 Refueling Outage ML18065A3751995-12-27027 December 1995 Application for Amend to License DPR-20,rewriting Electrical Power Sys Sections of TS & Bases to Closely Emulate STS ML18065A3461995-12-11011 December 1995 Application for Amend to License DPR-20,revising Administrative Controls Section to Emulate CE STS by Removing Review & Audit Requirements of Section 6.5 & Record Retention Requirements of Section 6.10 from TS ML18065A3321995-12-0606 December 1995 Application for Amend to License DPR-20,relocating Crane Operation & Movement of Heavy Loads Requirements & Bases from TS to Other Plant Documents Prior to 1996 Refueling Outage ML18065A1741995-10-17017 October 1995 Application for Amend to License DPR-20,changing Paragraph 2.B.(2) to Ref 10CFR40 & to Allow Use of Source Matls as Reactor Fuel,Rewording Paragraph 2.E & Deleting Paragraph 2.7 & Revising TS Pressurizer Cooldown Limit ML18064A8391995-07-0505 July 1995 Application for Amend to License DPR-20,deleting TS 6.4, Training & Revising TS 6.5.1.2 on Plant Review Committee Composition & 6.5.3.1 & 6.5.3.2,clarifying & Modifying Function & Composition of Plant Safety & Licensing Staff ML18064A7591995-05-0101 May 1995 Application for Amend to License DPR-20.Amend Would Place Requirements in TS Section 4.7 for Periodic DG Peak Load Tests ML18064A6121995-02-10010 February 1995 Application for Amend to License DPR-20,proposing One Time Deferral of 18-month Refueling Interval Surveillance Tests ML18064A5821995-01-13013 January 1995 Tech Specs Change Request to License DPR-20 Addressing Required Settings & Allowable as Found & as Left Tolerances for Primary & Secondary Safety Valves ML18064A5341994-12-29029 December 1994 Application for Amend to License DPR-20,revising TSs Re Iodine Removal Sys ML18064A5061994-12-13013 December 1994 Application for Amend to License DPR-20,adding Third High Thermal Performance DNB Correlation to Safety Limit 2.1 ML18064A4081994-10-0505 October 1994 Application for Amend to License DPR-20,revising TS Relating to Primary Coolant Sys pressure-temp Limits.Rev 0 to Engineering Analysis EA-A-PAL-92-095-01 & Excerpts from Rosemount Instruction Manual 4515,dtd Jan 1988 Encl ML18059B0961994-07-0707 July 1994 Application for Amend to License DPR-20,revising TS Re Shutdown Cooling.Changes Intended to Resolve Concerns Arose During NRC Review of Change Request ML18059A9751994-05-0505 May 1994 Application for Amend to License DPR-20,revising TS Re Shutdown Cooling.Changes Necessary Due to Intervening Amends Containing Listed Differences from Pages Submitted on 930519 ML18059A9321994-04-0707 April 1994 Application for Amend to License DPR-20,requesting TS Change Re Instrumentation & Control Section ML18059A9411994-04-0707 April 1994 Application for Amend to License DPR-20,relocating Cycle Specific Operating Limits to Colr,Per Guidance of GL 88-16, Removal of Cycle-Specific Parameter Limits from Ts. Proposed COLR Encl ML18059A8851994-03-11011 March 1994 Rev to 940222 I&C TS Change Request to License DPR-20,adding Surveillance Item 10 to Table 4.2.1 Which Require Verifying SIT Level & Pressure Each Shift & Adding Three Paragraphs to Basis for Proposed Section 3.17 ML18059A3721993-09-0303 September 1993 Changes to 930129 Application for Amend to License DPR-20, Modifying Radial Peaking Factor Limits in TS Table 3.23-2 to Incorporate Appropriate Limits for Modified L Fuel Assemblies Recently Installed in Reactor for Cycle 11 ML18058B8991993-06-25025 June 1993 Revises 921208 Application for Amend to License DPR-20 & Brings Proposed Specifications Closer to Model Tech Specs, While Retaining Necessary plant-specific Differences & Updating Proposed Pages to Reflect Amends 147 & 149 ML18058B7421993-03-29029 March 1993 Application for Amend to License DPR-20,changing TS to Required Frequency for Surveillance Test Which Requires Moving Each Control Rod to Once Each 92 Days Instead of Once Every 2 Wks ML18058B3881993-01-29029 January 1993 Application for Amend to License DPR-20,consisting of Proposed TS Changes to Table 3.23-2, Radiation Peaking Factor Limits for Cycle 11. Offsite Dose Calculations & EMF-92-178, Palisades Cycle 11:Disposition & ... Encl ML18058B3481993-01-19019 January 1993 Application for Amend to License DPR-20,changing Surveillance Interval for Testing Control Rod Drive mechanisms,CRD-20 & CRD-31 from Every Two Wks to Once in Mar 1993 ML18058A5631992-06-22022 June 1992 Suppl to 920317 Application for Amend to License DPR-20, Consisting of Revised Page 3-82 Re Shutdown Cooling ML18058A5561992-06-12012 June 1992 Application for Amend to License DPR-20,changing TS to Better Coordinate Required Action Statement of Electrical Sys Spec W/Lco to Allow Testing & Loading of DG When Plant Above 325 F But Not Yet Critical ML18058A5491992-06-12012 June 1992 Application for Amend to License DPR-20,changing TS to Delete Requirements Re Iodine Removal Sys Hydrazine Storage Tank Since Use of Hydrazine No Longer Considered in Current Rev of SRP ML18058A3631992-04-15015 April 1992 Application for Amend to License DPR-20,changing TSs to Incorporate Generic Ltr 90-06 PORV Requirements for Power Operation & Modifying Pcs Overpressure Protection Spec Venting Requirements ML18058A2921992-03-18018 March 1992 Application for Amend to License DPR-20,revising TS Re Shutdown Cooling ML18058A1541992-02-0303 February 1992 Application for Amend to License DPR-20,deleting Three Primary Coolant Pump Testing Requirements & Revising Safety Limits & Limiting Safety Sys Settings Specs to Enhance Clarity of Subj Requirements ML18057B3711991-11-12012 November 1991 Application for Amend to License DPR-20,revising Tech Specs to Remove Schedule for Withdrawal of Reactor Vessel Matl Specimens,Per Generic Ltr 91-01 ML18057B3481991-11-0101 November 1991 Application for Amend to License DPR-20,changing TS for Operation During Cycle 10 as Results of Changes to Fuel Design (Reload N) & Fuel Mgt Scheme for Low Leakage Core. Siemens Repts EMF-91-176 & EMF-91-177 Encl ML18057B3061991-09-27027 September 1991 Application for Amend to License DPR-20,proposing Change to Tech Spec 5.2.3.a Re Containment Air Cooler Design,Per 861020 & 870430 Requests ML18057B3021991-09-26026 September 1991 Application for Amend to License DPR-20,consisting of Rev 2 to 890628 Request,In Response to Recommendations of Generic Ltr 88-17 to Add Shutdown Cooling Sys Operability Requirements to Tech Specs ML18057B1681991-07-15015 July 1991 Application for Amend to License DPR-20,requesting Tech Spec Changes in Administrative Controls W/Emphasis on Changes in Engineering ML18057A9821991-06-13013 June 1991 Application for Amend to License DPR-20,revising Tech Specs to Incorporate Change to Inservice Insp Program for Shock Suppressors (Snubbers) ML18057A9631991-05-30030 May 1991 Application for Amend to License DPR-20,changing Tech Specs to Incorporate Change to Reactor Variable High Power Trip setpoint.ANF-90-181, Review & Analysis of SRP Chapter 15 Events for Palisades W/15% Variable High Power... Encl ML18057A9551991-05-28028 May 1991 Application for Amend to License DPR-20,changing Tech Specs Re Inservice Insp Program for Shock Suppressors (Snubbers) ML18057A8881991-05-0101 May 1991 Rev 1 to Application for Amend to License DPR-20,changing TS Re Shutdown Cooling Sys Per Generic Ltr 88-17,by Adding Operability Requirements for Shutdown Cooling Sys & Steam Generators ML18057A8291991-03-25025 March 1991 Application for Amend to License DPR-20,changing Tech Specs Section 4.5.2a(2) & 4.5.2b(3) 1998-06-17
[Table view] |
Text
consumers Power David W. Rogers Plant Safety and Licensing Director POWERINli MICHlliAN~S PRDliRESS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 April 7, 1994 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - TECHNICAL SPECIFICATIONS CHANGE REQUEST - INSTRUMENTATION AND CONTROL - ADDITIONAL HAZARDS ANALYSIS.
On November 15 1991, Consumers Power Company (CPCo) submitted a Technical Specifications (TS) change request which proposed completely rewritten requirements for the Instrument and Control (I&C) sections of the Palisades TS.
This change request contained a No Significant Hazards (NSH) analysis which addressed the proposed changes. On February 22 and March 11, 1994, CPCo submitted revisions and additions to the November 15, 1991 submittal, concluding in each case that the revisions did not alter the conclusions of the original NSH analysis.
It has come to our attention that the NSH analysis submitted on November 15, 1991 does not address all of the additions to that submittal which were subsequently proposed. This letter provides a general discussion of the proposed revisions and additions proposed in our February 22 and march 11, 1994 submittals. A NSH analysis, addressing those items not discussed in the 1991 submittal NSH analysis, is provided as Attachment 1.
The revisions and additions proposed to the 1991 submittal are as follows:
- 1) Changes to the affected pages made by intervening amendments,
- 2) Clarifications suggested by NRC and Palisades reviewers,
- 3) Addition of two instrument channels to the "Accident Monitoring Instruments" (AMI) Limiting Condition for Operation (LCO),
- 4) Deletion of surveillance requirements for Safety Injection Tank (SIT) instruments, as suggested by Generic Letter (GL) 93-05, and
- 5) Addition of a general "Applicability" LCO which appears in the Standard Technical Specifications (STS) but not in the Palisades TS.
~\
*-1:T4o415ois3 940407
~DR ADOCK Q500~5~5 A CMS' ENERGY COMPANY
Item 1 merely updates the submittal to reflect the current operating license, and need no further justification.
Item 2 simply enhances clarity and does not change any operating limits or requirements, or any conclusions of the NSH analysis submitted in 1991.
Item 3 is addressed by the NSH analysis submitted in 1991; that analysis addressed the addition of the entire AMI LCO. The two channels in question, steam generator narrow-range level instruments, were omitted from the AMI LCO of the 1991 submittal because they are required by the proposed (and existing)
Reactor Protective System (RPS) LCO. Subsequently, it was noted that the applicability of the RPS LCO was not the same as for the AMI LCO, therefore, the instrument channels were added to the AMI LCO and surveillance.
Item 4, deletion of requirements for the Safety Injection Tank instrument surveillance (as suggested in GL 93-05), is discussed in the NSH analysis provided in Attachment 1. Existing Palisades TS contain 3 surveillance requirements associated with the SIT instrument channels as items 13a, b, and c of Table 4.1.2. These are requirements for verification that SIT level and pressure are within limits, a instrument channel check, and an instrument channel calibration. Table 4.1.2 has been replaced with proposed Table 4.17.6.
Those items in existing Table 4.1.2 which are not related to instrument channel operability, such as verification of SIT level and pressure, have been moved to more appropriate sections of the TS. As proposed, the verification of SIT level and pressure appears, essentially unchanged, as item 10 of Table 4.2.2. The SIT instrument channel surveillance requirements have been deleted as suggested by GL 93-05.
Item 5, addition of LCO 3.0.5 from the STS (NUREG 1432), is also addressed in the NSH analysis provided in Attachment 1. One of the operational changes proposed for the I&C TS requires that an inoperable RPS channel be placed in the "TRIP" condition, eliminating the option for operation with a channel continuously bypassed. At Palisades, an RPS channel is placed in TRIP by actually de-energizing the trip unit module. The requirement to place a channel in TRIP, therefore, eliminates the possibility of post maintenance testing since such testing cannot be accomplished with the channel tripped (de-energized). This conflict was recognized during the writing of the new STS, NUREG 1432 etc; the subject LCO 3.0.5 was introduced as the result. That LCO would allow an inoperable channel, which had been placed in TRIP, to be repaired, tested, and returned to service. At the time the 1991 submittal was being prepared, NUREG 1432 had not been published.
A copy of thi~ letter has been sent to the State of Michigan.
~CJ.~
David W. Rogers Plant Safety and Licensing Director CC Administrator, Region III, USNRC Resident Inspector, Palisades Attachment