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| The new inspection schedule will still depend on the number of inoperable snubbers found duriflg the previous inspection, however, it will have the added advantage of being based on the percentage of the total number of snubbers inspected. | | The new inspection schedule will still depend on the number of inoperable snubbers found duriflg the previous inspection, however, it will have the added advantage of being based on the percentage of the total number of snubbers inspected. |
| Since the corifidence level as the existing schedule is maintained, it is concluded that the probability of a snubber failure, as a result of imposing this new inspection schedule, will not be increased. | | Since the corifidence level as the existing schedule is maintained, it is concluded that the probability of a snubber failure, as a result of imposing this new inspection schedule, will not be increased. |
| If the probability of a snubber failure will not increase, it can also be concluded that the consequences of an accident will not increase. | | If the probability of a snubber failure will not increase, it can also be concluded that the consequences of an accident will not increase. |
| : 2. Create the possibility of a new or different kind of accident from any previously evaluated. | | : 2. Create the possibility of a new or different kind of accident from any previously evaluated. |
| 3 The proposed technical specifications change does not create the possibility of a new or different kind of accident from any previously evaluated. | | 3 The proposed technical specifications change does not create the possibility of a new or different kind of accident from any previously evaluated. |
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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 POW ERi Nii MICHlliAN'S PROliRESS . Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Coven, Ml 49043 May 28, 1991 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 -LICENSE DPR-20 -PALISADES PLANT -GB Slade General Manager TECHNICAL SPECIFICATIONS CHANGE REQUEST -INSERVICE INSPECTION PROGRAM FOR SHOCK SUPPRESSORS (SNUBBERS)
Enclosed is a request for change to the Palisades Plant Technical Specifications to incorporate a change to the inservice inspection program for , shock suppressors (snubbers).
Attachment 1 of this submittal contains the proposed Technical Specifications pages and Attachment 2 has the existing Technical Specifications pages marked up to show the proposed changes. It is requested that this change be made #;;I:_ Gerald B Slade General Manager CC: Administrator, Region III, USNRC NRC Resident Inspector, Palisades Attachments 9106100042 910528 PDR ADOCK 05000255 P PDR A c.M5 ENER5Y COMPANY CONSUMERS POWER COMPANY Docket 50-255 Request for Change to the Technical Specifications License DPR-20 1 For the reasons hereinafter set forth, it is requested that the Technical Specifications contained in the Facility Operating License DPR-20, Docket 50-255, issued to Consumers Power Company on February 21, 1991, for the Palisades Plant be changed as described in Section I below: I. Changes Change Section 4.16.1 as follows: Replace the existing Section 4.16.1, Section 4.16.l(a) and Section 4.16.l(b) with new sections as shown in Attachment 2: II. Discussion This change to the Palisades Plant Technical Specifications is being initiated as a result of NRC Generic Letter 90-09, "Alternative Requirements for Snubber Visual Inspection Intervals and Corrective Actions." Generic Letter 90-09 discusses how the present snubber inspection interval schedule is based on the number of snubber failures from the previous visual inspection with no regard to the total number of snubbers inspected.
The existing requirements have created numerous hardships for utilities having large snubber populations.
Some licensees have spent a significant amount of resources and have subjected plant personnel to unnecessary exposure to comply with the existing visual inspection schedule.
To alleviate this situation, the NRC has developed an alternate schedule for visual inspections that maintains the same confidence level as the existing schedule and generally will allow the licensee to perform visual inspections and corrective actions during plant outages. Because this technical specification improvement will reduce future occupational radiation exposure and is highly cost effective, the alternative inspection schedule is consistent with the NRC's statement on technical specification improvements.
The new inspection schedule is_ based on the number of unacceptable snubbers found during the previous inspection in proportion to the sizes of the various snubber populations or categories.
A snubber is considered unacceptable if it fails the acceptance criteria of the visual inspection.
The new inspection schedule could allow up to 48 months between inspection intervals, depending on the number of unacceptable snubbers found during the previous inspection.
In addition, the new inspection schedule will not penalize the utility by imposing extremely short inspection intervals when a few snubbers *are found unacceptable.
It has been concluded that it would be in our best interest to implement this technical specifications change at Palisades since the potential for snubber failure does exist and complying with the present schedule could cause unnecessary and frequent plant shutdowns.
III. Analysis of No Significant Hazards Consideration Consumers Power Company finds that activities associated with this proposed technical specifications change involve no significant hazards; and accordingly, a no significant hazards determination per 10CFR50.92(c) is justified.
The following evaluation supports the finding that the proposed changes would not: 2 1. Involve a significant increase in the possibility or consequences of an accident previously evaluated.
The proposed technical specifications does not involve a significant increase in the possibility or consequences of an accident previously evaluated.
A safety related snubber is considered a passive device which is called upon to perform during a seismic or dynamic event, the failure of a snubber would have no effect on the probability of an accident.
The consequences of an accident previously evaluated in the FSAR will not be increased by changing the snubber visual inspection schedule in Technical Specification 4.16.1.a.
All safety related snubbers at Palisades are subjected to visual and functional.
testing. Functional testing provides a 95 percent confidence level that 90 to 100 percent of the snubbers will operate within the specified acceptance limits. The performance of visual examinations complement the functional testing program and provides additional confidence in snubber operability.
The existing snubber visual inspection schedule is based on the number of inoperable snubbers found during the previous inspection period with no regard to the total number of snubbers inspected.
The new inspection schedule will still depend on the number of inoperable snubbers found duriflg the previous inspection, however, it will have the added advantage of being based on the percentage of the total number of snubbers inspected.
Since the corifidence level as the existing schedule is maintained, it is concluded that the probability of a snubber failure, as a result of imposing this new inspection schedule, will not be increased.
If the probability of a snubber failure will not increase, it can also be concluded that the consequences of an accident will not increase.
- 2. Create the possibility of a new or different kind of accident from any previously evaluated.
3 The proposed technical specifications change does not create the possibility of a new or different kind of accident from any previously evaluated.
The change does not introduce any new equipment into the plant or require any existing equipment to be operated in a manner different than that in which it was designed to be operated.
A safety related snubber is considered a passive device which is called upon to perform during a seismic or dynamic event, therefore, the failure of a snubber would have no effect on the possibility of an accident.
Imposing a new inspection schedule will have no effect on the method or thoroughness of the snubber inspections.
The new schedule is an administrative control only. Therefore, the possibility of a malfunction of a different type than any previously evaluated in the FSAR will not be created. 3. Involve a significant reduction in the margin of safety. The proposed technical specifications change does not involve a significant reduction in the margin of safety. This change to the snubber inspection schedule maintains the same confidence level of snubber operability as the existing schedule and replaces it. As stated previously, the functional testing of the snubbers provides a 95 percent confidence level that 90 to 100 percent of the snubbers will operate within the specified acceptance limits. Therefore, the margin of safety as defined by plant licensing bases will not be reduced.
4 IV. Conclusion The Palisades Plant Review Committee has reviewed this Technical Specifications Change Request and has determined that this change does not involve an unreviewed safety question.
Further, the change involves no significant hazards consideration.
This change has been reviewed by the Nuclear Safety Services Department.
A copy of this Technical Specifications Change Request has been sent to the State of Michigan official designated to receive such Amendments to the Operating License. CONSUMERS POWER COMPANY To the best of my knowledge, information and belief, the contents of this Technical Specifications Change Request are truthful and complete.
By -------------
David P Hoffman, Vice President Nuclear Operations Sworn and subscribed to before me this_ day of ______ 1991. Notary Public , Michigan My commission expires October 11, 1993