ML18059A932

Application for Amend to License DPR-20,requesting TS Change Re Instrumentation & Control Section

ML18059A932
Person / Time
Site:	Palisades
Issue date:	04/07/1994
From:	ROGERS D W CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18059A933	List: ML18059A932 ML18059A934
References
NUDOCS 9404150183
Download: ML18059A932 (2)

Text

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.

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 ADOCK 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 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