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* ENCLOSURE CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 Request for Change to the Technical Specifications Remove Cross-Train Testing Requirements from LCO Action Statements | * ENCLOSURE CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 Request for Change to the Technical Specifications Remove Cross-Train Testing Requirements from LCO Action Statements | ||
----------------------9602150204* | - - - ----- -- - - ------ ---- | ||
960206 PDR ADOCK 05000255 p PDR CONSUMERS POWER COMPANY Docket 50-255 Request for Change to the Technical Specifications License DPR-20 It is requested that the Technical Specifications (TS) 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 below. These proposed changes will remove cross-train testing requirements from the Emergency Core Cooling System and Containment Cooling sections of the Palisades Technical Specifications. | 9602150204* 960206 PDR ADOCK 05000255 p PDR | ||
Two attachments are included with this TS change request: 1. The proposed TS pages 2. Existing pages marked to show the proposed changes This change request deletes the requirements in required action statements associated with two LCOs which require the corresponding redundant components to be tested when a required component becomes inoperable. | |||
In some cases, this testing is required to be completed prior to initiating repairs. These "cross-train" testing requirements appear in three sections of the Palisades Technical Specifications, Emergency Core Cooling System, LCO 3.3, Containment Cooling, LCO 3.4, and Electrical System, LCO 3.7. A Technical Specifications change request (TSCR) which rewrites the Electrical System Specification, emulating the Standard Technical Specifications and eliminating unnecessary cross-train testing, was submitted on December 27, 1995. This TSCR proposes removal of those cross-train testing requirements which remain. I. Changes Proposed: | ~ CONSUMERS POWER COMPANY Docket 50-255 | ||
: 1. Required Action Statements 3.3.2b, 3.3.2c, and 3.3.2f, on page 3-29a, are changed to delete the second sentence of each, which requires the subject cross-train testing, as shown: b. One low-pressure safety injection pump may be inoperable provided the pump is restored to operable status within 24 hours. -lfl.e ether law pressure safety iRjectieR pump shall be tested te demeAstrate eperability prier te iRitiatiRg repair ef the iReperable pump. c. One high-pressure safety injection pump may be inoperable provided the pump is restored to operable status within 24 hours. The ether high pressure safety iAjectieR pump shall be tested te demeAstrate eperability prier te iRitiatiRg repair ef the iAeperable pump. f. Any valve, interlock or pipe associated with the safety injection and shutdown cooling system and which is not covered under 3.3.2e above but, which is required to function during accident conditions, may be inoperable for a period of no more than 24 hours. Prier te iRitiatiRg repairs, all valves aRd iRterlecks iR the system that previde the duplicate fuAetieR shall be tested te demeRstrate eperability. | ~ | ||
* | Request for Change to the Technical Specifications License DPR-20 It is requested that the Technical Specifications (TS) 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 below. These proposed changes will remove cross-train testing requirements from the Emergency Core Cooling System and Containment Cooling sections of the Palisades Technical Specifications. | ||
* | Two attachments are included with this TS change request: | ||
testing. 3. Required Act-ion Statements 3.4.2, 3.4.3, and 3.4.5, on pages 3-34 and 3-35, are changed to delete the cross-train testing requirements, as shown: 3.4.2 | : 1. The proposed TS pages | ||
.. | : 2. Existing pages marked to show the proposed changes This change request deletes the requirements in required action statements associated with two LCOs which require the corresponding redundant components to be tested when a required component becomes inoperable. In some cases, this testing is required to be completed prior to initiating repairs. | ||
........ ...... | These "cross-train" testing requirements appear in three sections of the Palisades Technical Specifications, Emergency Core Cooling System, LCO 3.3, Containment Cooling, LCO 3.4, and Electrical System, LCO 3.7. A Technical Specifications change request (TSCR) which rewrites the Electrical System Specification, emulating the Standard Technical Specifications and eliminating unnecessary cross-train testing, was submitted on December 27, 1995. This TSCR proposes removal of those cross-train testing requirements which remain. | ||
I. Changes Proposed: | |||
: 1. Required Action Statements 3.3.2b, 3.3.2c, and 3.3.2f, on page 3-29a, are changed to delete the second sentence of each, which requires the subject cross-train testing, as shown: | |||
The redundant eempenent er system en the ether | : b. One low-pressure safety injection pump may be inoperable provided the pump is restored to operable status within 24 hours. -lfl.e ether law pressure safety iRjectieR pump shall be tested te demeAstrate eperability prier te iRitiatiRg repair ef the iReperable pump. | ||
Any valve, interlock or piping associated with the containment cooling system which is not covered under Specification 3.4.4 above and which is required to function during accident conditions may be inoperable for a period of no more than 24 hours pioevided that prier te initiating repairs, all valves and interleeks in the system that previde the duplicate funetien shall he tested te demenstrate eperahility. | : c. One high-pressure safety injection pump may be inoperable provided the pump is restored to operable status within 24 hours. | ||
The ether high pressure safety iAjectieR pump shall be tested te demeAstrate eperability prier te iRitiatiRg repair ef the iAeperable pump. | |||
: f. Any valve, interlock or pipe associated with the safety injection and shutdown cooling system and which is not covered under 3.3.2e above but, which is required to function during accident conditions, may be inoperable for a period of no more than 24 hours. Prier te iRitiatiRg repairs, all valves aRd iRterlecks iR the system that previde the duplicate fuAetieR shall be tested te demeRstrate eperability. | |||
is to be tested prior to initiating repair of the inoperable component." It is not clear, from the wording of the basis, whether this requirement was intended to apply prior to planned maintenance, prior to emergent restorative maintenance, or both. The wording of the required action statements does not differentiate. | |||
Contrary to the initi.al intent of these testing requirements, cross-train testing can actually reduce the assurance that redundant equipment.will function as designed. | 2. | ||
The required surveillance intervals have been shown, by operating experience, to provide adequate assurance that required equipment remains operable while reducing unnecessary equipment wear. Additional testing provides little added assurance of future operability, but contributes additional wear. In addition, testing of some equipment requires making that equipment inoperable during the test. If such testing must precede repair of its inoperable counterpart in the opposite train, a loss of safety function may occur during the testing period. In the particular instance which initiated this TSCR, maintenance on one train of high pressure control air, which provides motive power for valves in the ECCS system, would require depressurizing that train. The train testing requirement of Specification 3.3.2f would require testing of the comparable valves on the other train of ECCS. Test stroking of those valves, ECCS suction from the containment sump and from the Safety Injection Refueling Water Tank among others, should not be performed above Cold Shutdown due to the stroking affecting the operability of an entire train of Engineered Safety Features. | * | ||
Current NRC policy, as reflected in the Standard Technical Specifications, NUREGs 1430, 1431, 1432, 1433, and 1434, is that sufficient assurance that redundant components are operable and will function as designed is provided by performance of its routine surveillance testing, and the knowledge that it has no known deficiencies or open work orders. The removal of train testing requirements is discussed and encouraged in an April 10, 1992 NRC internal memo from Christopher I. Grimes to Robert A. Capra, et al. III. Analysis of No Significant Hazards Consideration Consumers Power Company finds that this proposed Technical Specifications change involves no significant hazards and, accordingly, that a no significant hazards determination per 10CFR50.92(c} | * The basts section for Specification 3.3, on page 3-32, is revised to delete reference to cross-train. testing. | ||
is justified. | 2 | ||
!...:.. Do the proposed changes involve a significant increase iri the probability or consequences of an accident previously evaluated? | : 3. Required Act-ion Statements 3.4.2, 3.4.3, and 3.4.5, on pages 3-34 and 3-35, are changed to delete the cross-train testing requirements, as shown: | ||
The proposed changes remove the requirement for testing which is in addition to the normal surveillance interval. | 3.4.2 During power operation, one of .the components listed in Specification 3.4.1 above may be inoperable previded that the eerioe spend i ng ioedund~~1. . £.~.ffl.P.. ~-~:i:!.~.~-~--~--~JJ.. . . . ~.§. . . 1~-~.!.j.~. . . J.e demenstioate epeioahi l i ty :~::Oiif'\a'trtef:l"wi'~'lfrP'un=~?tif=fs'eV:itF\~a~i If the tnoperable compon~h~£'''''''t'i~Hb'f"'*'''r~'s'£g'r~3'=*====t=~''*'*''op'e'r':'bti'°liy within 7 days, the reactor shall be placed in a hot shutdown condition. | ||
The affected equipment is subject to periodic surveillance testing required by the Technical Specifications. | 3.4.3 During power operation, the requirements of Specification 3.4.1 may be modified to allow a total of two of the components listed in Section 3.4.la orb to be inoperable at any one time pioevided the emergeney diesel eenneeted te the eppesite engineered safeguaiods hus is started te demenstrate eperahility. The redundant eempenent er system en the ether m~~~:H~:~~~~=~;~::*~~th~f components is not restored within 24 hours, the reactor shall be placed in a hot shutdown condition within 12 hours. | ||
Removing the requirement for additional testing cannot alter any plant operating conditions, operating practices, equipment settings, or equipment capabilities. | If the operability of at least one of the two inoperable components is not restored within an additional 48 hours, the reactor shall be placed in ~cold shutdown condition within 24 hours. Continued power operation with*one component out of service shall be as specified in Section 3.4.2, with the permissible period in inoperability starting at the. time that the first of the two components became inoperable. | ||
Therefore, changing an AOT or a surveillance interval cannot increase the probability or consequences of an accident previously evaluated. | 3.4.5 Any valve, interlock or piping associated with the containment cooling system which is not covered under Specification 3.4.4 above and which is required to function during accident conditions may be inoperable for a period of no more than 24 hours pioevided that prier te initiating repairs, all valves and interleeks in the system that previde the duplicate funetien shall he tested te demenstrate eperahility. | ||
II. Reasons for Changes: | |||
4 The proposed changes remove the requirement for testing which is in addition to the normal surveillance interval. | * | ||
The affected equipment is subject to periodic surveillance testing required by the Technical Specifications. | * 3 The original intent of these cross-train testing requirements, as described in the basis for Specification 3.3 was "To provide maximum assurance that the redundant component(s) will operate if required to do so, the redundant component(s} is to be tested prior to initiating repair of the inoperable component." It is not clear, from the wording of the basis, whether this requirement was intended to apply prior to planned maintenance, prior to emergent restorative maintenance, or both. The wording of the required action statements does not differentiate. | ||
Removing the requirement for additional testing cannot alter any plant operating conditions, operating practices, equipment settings, equipment capabilities. | Contrary to the initi.al intent of these testing requirements, cross-train testing can actually reduce the assurance that redundant equipment.will function as designed. The required surveillance intervals have been shown, by operating experience, to provide adequate assurance that required equipment remains operable while reducing unnecessary equipment wear. | ||
Therefore, changing an AOT or a surveillance interval cannot create the possibility of a new or different kind of accident from any previously evaluated . .3....:.. | Additional testing provides little added assurance of future operability, but contributes additional wear. In addition, testing of some equipment requires making that equipment inoperable during the test. If such testing must precede repair of its inoperable counterpart in the opposite train, a loss of safety function may occur during the testing period. | ||
Do the proposed changes involve a significant reduction in a margin of safety? The proposed changes remove the requirement for testing which is in addition to the normal surveillance interval, in effect extending the surveillance interval. | In the particular instance which initiated this TSCR, maintenance on one train of high pressure control air, which provides motive power for valves in the ECCS system, would require depressurizing that train. The cross-train testing requirement of Specification 3.3.2f would require testing of the comparable valves on the other train of ECCS. Test stroking of those valves, ECCS suction from the containment sump and from the Safety Injection Refueling Water Tank among others, should not be performed above Cold Shutdown due to the stroking affecting the operability of an entire train of Engineered Safety Features. | ||
An excessive surveillance interval extension could reduce the margin of safety by reducing assurance that required equipment will function as designed; an overly restrictive surveillance interval could also reduce the margin of safety by imposing unnecessary testing wear, equipment manipulations, and system transients on the plant. The existing requirements to perform cross-train testing were based on the operating experience available when they were added to the TS. Typically this was done during the initial plant licensing in 1971. The recently published Standard Technical Specifications (NUREG 1432) do not include cross-train testing requirements for the Engineered Safety Features components. | Current NRC policy, as reflected in the Standard Technical Specifications, NUREGs 1430, 1431, 1432, 1433, and 1434, is that sufficient assurance that redundant components are operable and will function as designed is provided by performance of its routine surveillance testing, and the knowledge that it has no known deficiencies or open work orders. The removal of cross-train testing requirements is discussed and encouraged in an April 10, 1992 NRC internal memo from Christopher I. Grimes to Robert A. Capra, et al. | ||
It has been judged by the NRC and by the industry, that cross-train testing is un-necessary, and that testing at normal surveillance intervals is adequate to assure equipment operability. | III. Analysis of No Significant Hazards Consideration Consumers Power Company finds that this proposed Technical Specifications change involves no significant hazards and, accordingly, that a no significant hazards determination per 10CFR50.92(c} is justified. | ||
This recent judgement is based on a much larger accumulation of operating experience than was available at the time Palisades was licensed. | !...:.. Do the proposed changes involve a significant increase iri the probability or consequences of an accident previously evaluated? | ||
There are no special features of the Palisades plant which would invalidate these more recent judgements of optimal testing requirements. | The proposed changes remove the requirement for testing which is in addition to the normal surveillance interval. The affected equipment is subject to periodic surveillance testing required by the Technical Specifications. Removing the requirement for additional testing cannot alter any plant operating conditions, operating practices, equipment settings, or equipment capabilities. Therefore, changing an AOT or a surveillance interval cannot increase the probability or consequences of an accident previously evaluated. | ||
Therefore, operation of the facility in accordance with the proposed changes will not involve a significant reduction in a margin of safety. IV. Conclusion The Palisades Plant Review Committee has reviewed this Technical Specifications Change Request and has determined that proposing this change does not involve an unreviewed safety question. | |||
Further, the change involves no significant hazards consideration. | 2...:.. | ||
This change has been reviewed by the Nuclear Performance Assessment Department. | * | ||
* ATTACHMENT 1 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 | * Do the proposed changes create the possibility of a new or different kind of accident from any previously evaluated? | ||
4 The proposed changes remove the requirement for testing which is in addition to the normal surveillance interval. The affected equipment is subject to periodic surveillance testing required by the Technical Specifications. Removing the requirement for additional testing cannot alter any plant operating conditions, operating practices, equipment settings, o~ equipment capabilities. Therefore, changing an AOT or a surveillance interval cannot create the possibility of a new or different kind of accident from any previously evaluated . | |||
! COOLING SYSTEM (Cont'd] | .3....:.. Do the proposed changes involve a significant reduction in a margin of safety? | ||
* During power operation the requirements of 3.3.1 may be modified to allow one of the following conditions to be true at any one time. If the system is not restored to meet the requirements of 3.3.1 within the time period specified below, the reactor shall be placed in a hot shutdown condition within 12 hours. If the requirements of 3.3.1 are not met within an additional 48 hours, the reactor shall be placed in a cold shutdown condition within 24 hours. a. One safety injection tank may be inoperable for a period of no more than one hour. b. One low-pressure safety injection pump may be inoperable provided the pump is restored to operable status with i.n 24 hours. c. One high-pressure safety injection pump may be inoperable provided the pump is restored to operable status within 24 hours. d. One shutdown heat exchanger and one component cooling water heat exchanger may be inoperable for a period of no more than 24 hours. e. Any valves, interlocks or piping directly associated with one of the above components and required to function during accident conditions shall be deemed to be part of that component and shall meet the same requirements as .listed for that component. | The proposed changes remove the requirement for testing which is in addition to the normal surveillance interval, in effect extending the surveillance interval. An excessive surveillance interval extension could reduce the margin of safety by reducing assurance that required equipment will function as designed; an overly restrictive surveillance interval could also reduce the margin of safety by imposing unnecessary testing wear, equipment manipulations, and system transients on the plant. | ||
: f. Any valve, interlock or pipe associated with the safety injection and shutdown cooling system and which is not under 3.3.2e above but, which is required to function during accident conditions, may be inoperable for a period of no more than 24 hours. 3-29a Amendment No. 1-, l-3.3 | The existing requirements to perform cross-train testing were based on the operating experience available when they were added to the TS. | ||
Typically this was done during the initial plant licensing in 1971. | |||
The recently published Standard Technical Specifications (NUREG 1432) do not include cross-train testing requirements for the Engineered Safety Features components. It has been judged by the NRC and by the industry, that cross-train testing is un-necessary, and that testing at normal surveillance intervals is adequate to assure equipment operability. This recent judgement is based on a much larger accumulation of operating experience than was available at the time Palisades was licensed. There are no special features of the Palisades plant which would invalidate these more recent judgements of optimal testing requirements. Therefore, operation of the facility in accordance with the proposed changes will not involve a significant reduction in a margin of safety. | |||
IV. Conclusion The Palisades Plant Review Committee has reviewed this Technical Specifications Change Request and has determined that proposing 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 Performance Assessment Department. | |||
* | |||
* ATTACHMENT 1 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 TECHNICAL SPECIFICATION CHANGE REQUEST REMOVAL OF CROSS TRAIN TESTING Replacement Proposed Pages | |||
3.3 3.3.2 EMERGENCY ! COOLING SYSTEM (Cont'd] | |||
* During power operation the requirements of 3.3.1 may be modified to allow one of the following conditions to be true at any one time. If the system is not restored to meet the requirements of 3.3.1 within the time period specified below, the reactor shall be placed in a hot shutdown condition within 12 hours. If the requirements of 3.3.1 are not met within an additional 48 hours, the reactor shall be placed in a cold shutdown condition within 24 hours. | |||
: a. One safety injection tank may be inoperable for a period of no more than one hour. | |||
: b. One low-pressure safety injection pump may be inoperable provided the pump is restored to operable status with i.n 24 hours. | |||
: c. One high-pressure safety injection pump may be inoperable provided the pump is restored to operable status within 24 hours. | |||
: d. One shutdown heat exchanger and one component cooling water heat exchanger may be inoperable for a period of no more than 24 hours. | |||
: e. Any valves, interlocks or piping directly associated with one of the above components and required to function during accident conditions shall be deemed to be part of that component and shall meet the same requirements as .listed for that component. | |||
: f. Any valve, interlock or pipe associated with the safety injection and shutdown cooling system and which is not cover~d under 3.3.2e above but, which is required to function during accident conditions, may be inoperable for a period of no more than 24 hours. | |||
3-29a Amendment No. 1-, l- | |||
3.3 Basis (continued) | |||
* EMERGENCY CORE COOLING SYSTEM | * EMERGENCY CORE COOLING SYSTEM | ||
* | * ability to tolerate additional equipment failures. If it develops that (a) the inoperable component is not repaired within the specified allowable time period; or (b) a second component in the same or related system is found to be inoperable, the reactor will initially be put in the hot shutdown condition to provide for reduction of the decay heat from the fuel and consequent reduction of cooling requirements after a postulated loss-of-coolant accident. This will also permit improved access for repairs in some cases. After a limited time in hot shutdown if the malfunction(s) is not corrected, the reactor will be placed in the cold shutdown condition utilizing normal shutdown and cooldown procedures. In the cold shutdown condition release of fission products or damage of the fuel elements is not considered possible. | ||
If it develops that (a) the inoperable component is not repaired within the specified allowable time period; or (b) a second component in the same or related system is found to be inoperable, the reactor will initially be put in the hot shutdown condition to provide for reduction of the decay heat from the fuel and consequent reduction of cooling requirements after a postulated coolant accident. | |||
This will also permit improved access for repairs in some cases. After a limited time in hot shutdown if the malfunction(s) is not corrected, the reactor will be placed in the cold shutdown condition utilizing normal shutdown and cooldown procedures. | |||
In the cold shutdown condition release of fission products or damage of the fuel elements is not considered possible. | |||
The plant operating procedures will require immediate action to effect repairs of an inoperable component and, therefore, in most cases, repairs will be completed in less than the specified allowable repair times. The limiting times to repair are intended to: (1) Assure that operability of the component will be restored promptly and yet, (2) allow sufficient time to effect repairs using safe and proper procedures. | The plant operating procedures will require immediate action to effect repairs of an inoperable component and, therefore, in most cases, repairs will be completed in less than the specified allowable repair times. The limiting times to repair are intended to: (1) Assure that operability of the component will be restored promptly and yet, (2) allow sufficient time to effect repairs using safe and proper procedures. | ||
The requirement for core cooling in case of a postulated loss-of-coolant accident while in the hot shutdown condition is significantly reduced below the requirements for a postulated loss-of-coolant accident during power operation. | The requirement for core cooling in case of a postulated loss-of-coolant accident while in the hot shutdown condition is significantly reduced below the requirements for a postulated loss-of-coolant accident during power operation. Putting the reactor in the hot shutdown condition reduces the consequences of a loss-of-coolant accident and also allows more free access to some of the engineered safeguards components in order to effect repairs. | ||
Putting the reactor in the hot shutdown condition reduces the consequences of a loss-of-coolant accident and also allows more free access to some of the engineered safeguards components in order to effect repairs. Failure to complete repairs within 48 hours of going to the hot shutdown condition is considered indicative of a requirement for major maintenance and, therefore, in such a case, the reactor is to be put into the cold shutdown condition. | Failure to complete repairs within 48 hours of going to the hot shutdown condition is considered indicative of a requirement for major maintenance and, therefore, in such a case, the reactor is to be put into the cold shutdown condition. | ||
With respect to the core cooling function, there is functional redundancy over most of the range of break Adequate core cooling for the break spectrum up to and including the 42-inch double-ended break is assured with the minimum safety injection which is defined as follows: For the system of four passive safety injection tanks, the entire contents of one tank are assumed to be unavailable for emergency core cooling. In addition, of the two high-pressure safety injection pumps and the two low-pressure safety injection pumps, only one of each type is assumed to operate; and also that 25% of their combined discharge rate is lost from the primary coolant system out the break. The transient hot spot fuel clad temperatures for the break sizes considered are shown on FSAR Figures 14.17.9 to 14.17.13. | With respect to the core cooling function, there is functional redundancy over most of the range of break sizes. 1 ~ | ||
These 3-32 Amendment No. -96, .J-1.+ | Adequate core cooling for the break spectrum up to and including the 42-inch double-ended break is assured with the minimum safety injection which is defined as follows: For the system of four passive safety injection tanks, the entire contents of one tank are assumed to be unavailable for emergency core cooling. In addition, of the two high-pressure safety injection pumps and the two low-pressure safety injection pumps, only one of each type is assumed to operate; and also that 25% of their combined discharge rate is lost from the primary coolant system out the break. The transient hot spot fuel clad temperatures for the break sizes considered are shown on FSAR Figures 14.17.9 to 14.17.13. These 3-32 Amendment No. -96, .J-1.+ | ||
3.4 | |||
* | 3.4 CONTAINMEN~OLING Applicability | ||
Specifications Containment Cooling Systems 3.4.1 The reactor shall not be made critical, except for low-temperature physics tests, unless all the following conditions are met: | * Applies to the operating status of the containment cooling systems. | ||
Containment Air Cooler VlA Air Cooler V2A Containment Air Cooler V3A Service Water Pump P7A Service Water Pump P7C Containment Spray Pump P54A Component Cooling Water Pump P528 b. The following equipment associated with diesel generator 1-1 is operable: | Objective To assure operability of equipment required to remove heat from the containment in normal operating and emergency situations. | ||
Service Water Pump P78 Containment Spray Pump P548 Containment Spray Pump P54C Component Cooling Water Pump P52A Component Cooling Water Pump P52C c. All heat exchangers, valves, piping and interlocks associated with the above components and required to function during accident conditions are operable. | Specifications Containment Cooling Systems 3.4.1 The reactor shall not be made critical, except for low-temperature physics tests, unless all the following conditions are met: | ||
During power operation, one of the components listed in Specification 3.4.1 above may be inoperable for a period of up to seven days. If the inoperable component is not restored to operability within 7 days, the reactor shall be placed in a hot shutdown condition. | : a. The following equipment associated with diesel generator 1-2 is operable: | ||
3-34 Amendment No. +/-94 3.4 | Containment Air Cooler VlA Contai~ment Air Cooler V2A Containment Air Cooler V3A Service Water Pump P7A Service Water Pump P7C Containment Spray Pump P54A Component Cooling Water Pump P528 | ||
* within 12 h-ours. If the inoperable component is not restored to operability within an additional 48 hours, the reactor shall be pl aced in a cold shutdown condition within 24 hours. During power operation, the requirements of Specification 3.4.1 may be modified to allow a total of two of the components listed in Section 3.4.la or b to be inoperable at any one time for a period of up to 24 hours. If the operability of at least one of the two inoperable components is not restored within 24 hours, the reactor shall be placed in a hot shutdown condition within 12 hours. If the operability of at least one of the two inoperable components is not restored within an additional 48 hours, the reactor shall be placed in a cold shutdown condition within 24 hours. Continued power operation with one component out of service shall be as specified in Section 3.4.2, with the permissible period in inoperability starting at the time that the first of the two components became inoperable. | : b. The following equipment associated with diesel generator 1-1 is operable: | ||
Any valves, interlocks and piping directly associated with one of the above components and required to function during accident conditions shall be deemed to be part of that component and shall meet the same requirements as listed for that component. | Service Water Pump P78 Containment Spray Pump P548 Containment Spray Pump P54C Component Cooling Water Pump P52A Component Cooling Water Pump P52C | ||
Any valve, interlock or piping associated with the containment cooling system which is not covered under Specification 3.4.4 above and which is required to function during accident conditions may be inoperable for a period of no more than 24 hours. 3-35 Amendment No. 2-, !04 | : c. All heat exchangers, valves, piping and interlocks associated with the above components and required to function during accident conditions are operable. | ||
. ** -... | 3.4.2 During power operation, one of the components listed in Specification 3.4.1 above may be inoperable for a period of up to seven days. If the inoperable component is not restored to operability within 7 days, the reactor shall be placed in a hot shutdown condition. | ||
* ATTACHMENT 2 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 TECHNICAL SPECIFICATION CHANGE REQUEST REMOVAL OF CROSS TRAIN TESTING Existing Pages Marked to Show Changes 3.3 | 3-34 Amendment No. +/-94 | ||
3.4 CONTAINMENT CO~G (Cont'd) | |||
* within 12 h-ours. If the inoperable component is not restored to operability within an additional 48 hours, the reactor shall be pl aced in a cold shutdown condition within 24 hours. | |||
3.4.3 During power operation, the requirements of Specification 3.4.1 may be modified to allow a total of two of the components listed in Section 3.4.la or b to be inoperable at any one time for a period of up to 24 hours. If the operability of at least one of the two inoperable components is not restored within 24 hours, the reactor shall be placed in a hot shutdown condition within 12 hours. If the operability of at least one of the two inoperable components is not restored within an additional 48 hours, the reactor shall be placed in a cold shutdown condition within 24 hours. Continued power operation with one component out of service shall be as specified in Section 3.4.2, with the permissible period in inoperability starting at the time that the first of the two components became inoperable. | |||
3.4.4 Any valves, interlocks and piping directly associated with one of the above components and required to function during accident conditions shall be deemed to be part of that component and shall meet the same requirements as listed for that component. | |||
3.4.5 Any valve, interlock or piping associated with the containment cooling system which is not covered under Specification 3.4.4 above and which is required to function during accident conditions may be inoperable for a period of no more than 24 hours. | |||
3-35 Amendment No. 2-, !04 | |||
. ** - ... | |||
* ATTACHMENT 2 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 TECHNICAL SPECIFICATION CHANGE REQUEST REMOVAL OF CROSS TRAIN TESTING Existing Pages Marked to Show Changes | |||
3.3 EMERGENCY ~E COOLING SYSTEM (Cont'd) 3.3.2 During power operation the requirements of 3.3.1 may be modified to a1low one of the following conditions to be true at any one time. If the system is not restored to meet the requirements of 3.3.1 within the time period specified below, the reactor shall be placed in a hot shutdown condition within 12 hours. If the requirements of 3.3.1 are not met within an additional 48 hours, the reactor shall be placed in a cold shutdown condition within 24 hours. | |||
a." One safety injection tank may be inoperable for a period of no more than one hour. | |||
: b. One low-pressure safety injection pump may be inoperable provided the pump is restored to operable status within 24 hours. The other 10*1 pressijre safety iAjeetioA pijmp shall be tested to demoAstrate operability prier to iAitiatiAg repair of the iAoperable pijmp. | |||
: c. One high-pressure safety injection pump may be inoperable provided the pump is restored to operable status within 24 hours. The other high pressijre safety iAjeetioA pijmp shall be tested to demoAstrate operability prior to iAitiatiAg repair of the iAopcrable pijmp. | |||
: d. One shutdown heat exchanger and one component cooling water heat exchanger may be inoperable for a period of no more than 24 hours. | |||
: e. Any valves, interlocks or piping directly associated with one of the above components and required to function during accident conditions shall be deemed to be part of that component and shall meet the same requirements as listed for that component. | |||
: f. Any valve, interlock or pipe associated with the safety injection and shutdown cooling system and which is not covered under 3.3.2e above but, which is required to function during accident conditions, may be inoperable for a period of no more than 24 hours. Prier to iAitiatiAg repairs, all valves aAd iAterleeks iA the system that provide the dijplieate fijAetioA shall be tested to demoAstrate operability. | : f. Any valve, interlock or pipe associated with the safety injection and shutdown cooling system and which is not covered under 3.3.2e above but, which is required to function during accident conditions, may be inoperable for a period of no more than 24 hours. Prier to iAitiatiAg repairs, all valves aAd iAterleeks iA the system that provide the dijplieate fijAetioA shall be tested to demoAstrate operability. | ||
3-29a Amendment No. -2+, l | 3-29a Amendment No. -2+, l | ||
.* 3.3 EMERGENCY CORE,LING SYSTEM | |||
Te pPe¥iae maximum assuPaAee that the PeauAaaAt eempeAeAt(s) will epePate if PequiPea te ae se, the PeauAaaAt eempeAeAt(s) is he tested pPieP te iAittatiAg pepaiP ef the eempeAeAt. | .* 3.3 EMERGENCY CORE,LING SYSTEM | ||
If it develops that (a) the inoperable component is not repaired within the specified allowable time period; -0r (b) a second component in the same or related system is found to be inoperable; the reactor will initially be put in the hot shutdown condition to provide for reduction of the decay heat from the fuel and consequent reduction of cooling requirements after a postulated loss-of-coolant accident. | *. | ||
This will also permit improved access for repairs in some cases.* After a limited time in hot shutdown if the malfunction(s) is not corrected, the reactor will be placed in the cold shutdown condition utilizing normal shutdown and cooldown procedures. | : | ||
In the cold shutdown condition release of fission products or damage of the fuel elements is not considered possible. | ~/ | ||
Basis (continued) ability to tolerate additional equipment failures. Te pPe¥iae maximum assuPaAee that the PeauAaaAt eempeAeAt(s) will epePate if PequiPea te ae se, the PeauAaaAt eempeAeAt(s) is t~ he tested pPieP te iAittatiAg pepaiP ef the iAepePahl~ eempeAeAt. If it develops that (a) the inoperable component is not repaired within the specified allowable time period; -0r (b) a second component in the same or related system is found to be inoperable; the reactor will initially be put in the hot shutdown condition to provide for reduction of the decay heat from the fuel and consequent reduction of cooling requirements after a postulated loss-of-coolant accident. This will also permit improved access for repairs in some cases.* After a limited time in hot shutdown if the malfunction(s) is not corrected, the reactor will be placed in the cold shutdown condition utilizing normal shutdown and cooldown procedures. In the cold shutdown condition release of fission products or damage of the fuel elements is not considered possible. | |||
The plant operating procedures will require immediate action to effect repairs of an inoperable component and, therefore, in most cases, repairs will be completed in less than the specified allowable repair times. The limiting times to repair are intended to: (1) Assure that operability of the component will be restored promptly and yet, (2) allow sufficient time to effect repairs using safe and proper procedures. | The plant operating procedures will require immediate action to effect repairs of an inoperable component and, therefore, in most cases, repairs will be completed in less than the specified allowable repair times. The limiting times to repair are intended to: (1) Assure that operability of the component will be restored promptly and yet, (2) allow sufficient time to effect repairs using safe and proper procedures. | ||
The requirement for core cooling in case of a postulated loss-of-coolant accident while in the hot shutdown condition is significantly reduced below the requirements for a postulated accident during power operation. | The requirement for core cooling in case of a postulated loss-of-coolant accident while in the hot shutdown condition is significantly reduced below the requirements for a postulated loss-~f-coolant accident during power operation. Putting the reactor in the hot shutdown condition reduces the consequences of a loss-of-coolant a~cident and also allows more free access to some of the engineered safeguards components in order to effect repairs. | ||
Putting the reactor in the hot shutdown condition reduces the consequences of a loss-of-coolant and also allows more free access to some of the engineered safeguards components in order to effect repairs. Failure to complete repairs within 48 hours of going the hot shutdown condition is considered indicative of a requirement for major maintenance and, therefore, in such a case, the reactor is to be put into the cold shutdown condition. | Failure to complete repairs within 48 hours of going t~ the hot shutdown condition is considered indicative of a requirement for major maintenance and, therefore, in such a case, the reactor is to be put into the cold shutdown condition. | ||
With respect to the core cooling function, there is functional redundancy over most of the range of break sizes. 121 | With respect to the core cooling function, there is functional redundancy over most of the range of break sizes. 121 | ||
* Adequate core cooling for the break spectrum up to and including the 42-inch double-ended break is assured with the minimum safety injection which is defined as follows: For the system of four passive safety injection tanks, the entire contents of one tank are assumed to be unavailable for emergency core cooling. In addition, of the two high-pressure safety _injection pumps and the two low-pressure safety injection pumps, only one of each type is assumed to operate; and also that 25% of their combined discharge rate is lost from the primary coolant system out the break. The transient hot spot fuel clad temperatures for the break sizes considered are shown on FSAR Figures 14.17.9 to 14.17.13. | * Adequate core cooling for the break spectrum up to and including the 42-inch double-ended break is assured with the minimum safety injection which is defined as follows: For the system of four passive safety injection tanks, the entire contents of one tank are assumed to be unavailable for emergency core cooling. In addition, of the two high-pressure safety _injection pumps and the two low-pressure safety injection pumps, only one of each type is assumed to operate; and also that 25% of their combined discharge rate is lost from the primary coolant system out the break. The transient hot spot fuel clad temperatures for the break sizes considered are shown on FSAR Figures 14.17.9 to 14.17.13. These 3-32 Amendment No. -96, -l-l-7 | ||
These 3-32 Amendment No. -96, -l-l-7 3.4 | |||
* | 3.4 CONTAINMEN~OLING Applicability | ||
Specifications Containment Cooling Systems The reactor shall not be made critical, except for low-temperature physics tests, unless all the following conditions are met: a. The following equipment associated with diesel generator 1-2 is operable: | * Applies to the operating status of the containment cooling systems. | ||
Containment Air Cooler VIA Containment Air Cooler V2A Containment Air Cooler V3A Service Water Pump P7A Service Water Pump P7C Containment Spray Pump P54A Component Cooling Water Pump P52B *b. The following equipment associated with diesel generator 1-1 is operable: | Objective To assure operability of equipment required to remove heat from the containment in normal operating and emergency situations. | ||
Service Water Pump P7B Containment Spray Pump P54B Containment Spray Pump P54C Component Cooling Water Pump P52A Component Cooling Water Pump P52C c. All heat exchangers, valves, piping and interlocks associated with the above components and required to function during accident conditions are operable. | Specifications Containment Cooling Systems 3.4.1 The reactor shall not be made critical, except for low-temperature physics tests, unless all the following conditions are met: | ||
During power operation, one of the components listed in Specification 3.4.1 above may be inoperable previaea that the cerrespeRaiRg reaijRaaRt cempeReRts shall be tested te acmeRstrate eperaeility for a period of up to seven days. If the inoperable component is not restored to operability within 7 days, the reactor shall be placed in a hot shutdown condition. | : a. The following equipment associated with diesel generator 1-2 is operable: | ||
3-34 Amendment No. -l-G4 3.4 | Containment Air Cooler VIA Containment Air Cooler V2A Containment Air Cooler V3A Service Water Pump P7A Service Water Pump P7C Containment Spray Pump P54A Component Cooling Water Pump P52B | ||
* within 12 hours; If the inoperable component is not restored to operability within an additional 48 hours, the reactor shall be placed in a cold shutdown condition within 24 hours. During power operation, the requirements of Specification 3.4.1 may be modified to allow a total of two of the components listed in Section 3.4.la or b to be inoperable at any one time previded the emergeAcy diesel ceAAected te the eppesite eAgiAeered safeguards bus is started te demeAstrate eperability. | *b. The following equipment associated with diesel generator 1-1 is operable: | ||
The reduAdaAt cempeAeAt er system eA the ether bus shall be tested befere iAitiatiAg maiAteAaAce eA the iAeperable cempeAeAts for a period of up to 24 hours. If the operability of at least one of the two inoperable components is not restored within 24 hours, the reactor shall be placed in a hot shutdown condition within 12 hours. If the operability of at least one of the two inoperable components is not restored within an additional 48 hours, the reactor shall be placed in a cold shutdown condition within 24 hours. Continued power operation with one component out of service shall be as specified in Section 3.4.2, with the permissible period in inoperability starting at the time that the first of the two components became inoperable. | Service Water Pump P7B Containment Spray Pump P54B Containment Spray Pump P54C Component Cooling Water Pump P52A Component Cooling Water Pump P52C | ||
Any valves, interlocks and piping directly associated with one of the above components and required to function during accident conditions shall be deemed to be part of that component and shall meet the same requirements as listed for that component. | : c. All heat exchangers, valves, piping and interlocks associated with the above components and required to function during accident conditions are operable. | ||
Any valve, interlock or piping associated with the containment cooling system which is not covered under Specification 3.4.4 above and which is required to function during accident conditions may be inoperable for a period of no more than 24 hours previded that prier te iAitiatiAg repairs, all valves aAd iAterlecks iA the system that previde the duplicate fuActieA shall be tested te demeAstrate eperability. | 3.4.2 During power operation, one of the components listed in Specification 3.4.1 above may be inoperable previaea that the cerrespeRaiRg reaijRaaRt cempeReRts shall be tested te acmeRstrate eperaeility for a period of up to seven days. If the inoperable component is not restored to operability within 7 days, the reactor shall be placed in a hot shutdown condition. | ||
3-34 Amendment No. -l-G4 | |||
3.4 CONTAINMENT CO~NG (Cont'd) | |||
* within 12 hours; If the inoperable component is not restored to operability within an additional 48 hours, the reactor shall be placed in a cold shutdown condition within 24 hours. | |||
3.4.3 During power operation, the requirements of Specification 3.4.1 may be modified to allow a total of two of the components listed in Section 3.4.la or b to be inoperable at any one time previded the emergeAcy diesel ceAAected te the eppesite eAgiAeered safeguards bus is started te demeAstrate eperability. The reduAdaAt cempeAeAt er system eA the ether bus shall be tested befere iAitiatiAg maiAteAaAce eA the iAeperable cempeAeAts for a period of up to 24 hours. If the operability of at least one of the two inoperable components is not restored within 24 hours, the reactor shall be placed in a hot shutdown condition within 12 hours. If the operability of at least one of the two inoperable components is not restored within an additional 48 hours, the reactor shall be placed in a cold shutdown condition within 24 hours. Continued power operation with one component out of service shall be as specified in Section 3.4.2, with the permissible period in inoperability starting at the time that the first of the two components became inoperable. | |||
3.4.4 Any valves, interlocks and piping directly associated with one of the above components and required to function during accident conditions shall be deemed to be part of that component and shall meet the same requirements as listed for that component. | |||
3.4.5 Any valve, interlock or piping associated with the containment cooling system which is not covered under Specification 3.4.4 above and which is required to function during accident conditions may be inoperable for a period of no more than 24 hours previded that prier te iAitiatiAg repairs, all valves aAd iAterlecks iA the system that previde the duplicate fuActieA shall be tested te demeAstrate eperability. | |||
3-35 Amendment No. 2-, lG4}} | 3-35 Amendment No. 2-, lG4}} |
Revision as of 18:02, 21 October 2019
ML18065A491 | |
Person / Time | |
---|---|
Site: | Palisades ![]() |
Issue date: | 02/06/1996 |
From: | CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
To: | |
Shared Package | |
ML18065A490 | List: |
References | |
NUDOCS 9602150204 | |
Download: ML18065A491 (15) | |
Text
- ENCLOSURE CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 Request for Change to the Technical Specifications Remove Cross-Train Testing Requirements from LCO Action Statements
- - - ----- -- - - ------ ----
9602150204* 960206 PDR ADOCK 05000255 p PDR
~ CONSUMERS POWER COMPANY Docket 50-255
~
Request for Change to the Technical Specifications License DPR-20 It is requested that the Technical Specifications (TS) 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 below. These proposed changes will remove cross-train testing requirements from the Emergency Core Cooling System and Containment Cooling sections of the Palisades Technical Specifications.
Two attachments are included with this TS change request:
- 1. The proposed TS pages
- 2. Existing pages marked to show the proposed changes This change request deletes the requirements in required action statements associated with two LCOs which require the corresponding redundant components to be tested when a required component becomes inoperable. In some cases, this testing is required to be completed prior to initiating repairs.
These "cross-train" testing requirements appear in three sections of the Palisades Technical Specifications, Emergency Core Cooling System, LCO 3.3, Containment Cooling, LCO 3.4, and Electrical System, LCO 3.7. A Technical Specifications change request (TSCR) which rewrites the Electrical System Specification, emulating the Standard Technical Specifications and eliminating unnecessary cross-train testing, was submitted on December 27, 1995. This TSCR proposes removal of those cross-train testing requirements which remain.
I. Changes Proposed:
- 1. Required Action Statements 3.3.2b, 3.3.2c, and 3.3.2f, on page 3-29a, are changed to delete the second sentence of each, which requires the subject cross-train testing, as shown:
- b. One low-pressure safety injection pump may be inoperable provided the pump is restored to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. -lfl.e ether law pressure safety iRjectieR pump shall be tested te demeAstrate eperability prier te iRitiatiRg repair ef the iReperable pump.
- c. One high-pressure safety injection pump may be inoperable provided the pump is restored to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The ether high pressure safety iAjectieR pump shall be tested te demeAstrate eperability prier te iRitiatiRg repair ef the iAeperable pump.
- f. Any valve, interlock or pipe associated with the safety injection and shutdown cooling system and which is not covered under 3.3.2e above but, which is required to function during accident conditions, may be inoperable for a period of no more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Prier te iRitiatiRg repairs, all valves aRd iRterlecks iR the system that previde the duplicate fuAetieR shall be tested te demeRstrate eperability.
2.
- The basts section for Specification 3.3, on page 3-32, is revised to delete reference to cross-train. testing.
2
- 3. Required Act-ion Statements 3.4.2, 3.4.3, and 3.4.5, on pages 3-34 and 3-35, are changed to delete the cross-train testing requirements, as shown:
3.4.2 During power operation, one of .the components listed in Specification 3.4.1 above may be inoperable previded that the eerioe spend i ng ioedund~~1. . £.~.ffl.P.. ~-~:i:!.~.~-~--~--~JJ.. . . . ~.§. . . 1~-~.!.j.~. . . J.e demenstioate epeioahi l i ty :~::Oiif'\a'trtef:l"wi'~'lfrP'un=~?tif=fs'eV:itF\~a~i If the tnoperable compon~h~£''t'i~Hb'f"'*r~'s'£g'r~3'=*====t=~*'*op'e'r':'bti'°liy within 7 days, the reactor shall be placed in a hot shutdown condition.
3.4.3 During power operation, the requirements of Specification 3.4.1 may be modified to allow a total of two of the components listed in Section 3.4.la orb to be inoperable at any one time pioevided the emergeney diesel eenneeted te the eppesite engineered safeguaiods hus is started te demenstrate eperahility. The redundant eempenent er system en the ether m~~~:H~:~~~~=~;~::*~~th~f components is not restored within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the reactor shall be placed in a hot shutdown condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
If the operability of at least one of the two inoperable components is not restored within an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the reactor shall be placed in ~cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Continued power operation with*one component out of service shall be as specified in Section 3.4.2, with the permissible period in inoperability starting at the. time that the first of the two components became inoperable.
3.4.5 Any valve, interlock or piping associated with the containment cooling system which is not covered under Specification 3.4.4 above and which is required to function during accident conditions may be inoperable for a period of no more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> pioevided that prier te initiating repairs, all valves and interleeks in the system that previde the duplicate funetien shall he tested te demenstrate eperahility.
II. Reasons for Changes:
- 3 The original intent of these cross-train testing requirements, as described in the basis for Specification 3.3 was "To provide maximum assurance that the redundant component(s) will operate if required to do so, the redundant component(s} is to be tested prior to initiating repair of the inoperable component." It is not clear, from the wording of the basis, whether this requirement was intended to apply prior to planned maintenance, prior to emergent restorative maintenance, or both. The wording of the required action statements does not differentiate.
Contrary to the initi.al intent of these testing requirements, cross-train testing can actually reduce the assurance that redundant equipment.will function as designed. The required surveillance intervals have been shown, by operating experience, to provide adequate assurance that required equipment remains operable while reducing unnecessary equipment wear.
Additional testing provides little added assurance of future operability, but contributes additional wear. In addition, testing of some equipment requires making that equipment inoperable during the test. If such testing must precede repair of its inoperable counterpart in the opposite train, a loss of safety function may occur during the testing period.
In the particular instance which initiated this TSCR, maintenance on one train of high pressure control air, which provides motive power for valves in the ECCS system, would require depressurizing that train. The cross-train testing requirement of Specification 3.3.2f would require testing of the comparable valves on the other train of ECCS. Test stroking of those valves, ECCS suction from the containment sump and from the Safety Injection Refueling Water Tank among others, should not be performed above Cold Shutdown due to the stroking affecting the operability of an entire train of Engineered Safety Features.
Current NRC policy, as reflected in the Standard Technical Specifications, NUREGs 1430, 1431, 1432, 1433, and 1434, is that sufficient assurance that redundant components are operable and will function as designed is provided by performance of its routine surveillance testing, and the knowledge that it has no known deficiencies or open work orders. The removal of cross-train testing requirements is discussed and encouraged in an April 10, 1992 NRC internal memo from Christopher I. Grimes to Robert A. Capra, et al.
III. Analysis of No Significant Hazards Consideration Consumers Power Company finds that this proposed Technical Specifications change involves no significant hazards and, accordingly, that a no significant hazards determination per 10CFR50.92(c} is justified.
!...:.. Do the proposed changes involve a significant increase iri the probability or consequences of an accident previously evaluated?
The proposed changes remove the requirement for testing which is in addition to the normal surveillance interval. The affected equipment is subject to periodic surveillance testing required by the Technical Specifications. Removing the requirement for additional testing cannot alter any plant operating conditions, operating practices, equipment settings, or equipment capabilities. Therefore, changing an AOT or a surveillance interval cannot increase the probability or consequences of an accident previously evaluated.
2...:..
- Do the proposed changes create the possibility of a new or different kind of accident from any previously evaluated?
4 The proposed changes remove the requirement for testing which is in addition to the normal surveillance interval. The affected equipment is subject to periodic surveillance testing required by the Technical Specifications. Removing the requirement for additional testing cannot alter any plant operating conditions, operating practices, equipment settings, o~ equipment capabilities. Therefore, changing an AOT or a surveillance interval cannot create the possibility of a new or different kind of accident from any previously evaluated .
.3....:.. Do the proposed changes involve a significant reduction in a margin of safety?
The proposed changes remove the requirement for testing which is in addition to the normal surveillance interval, in effect extending the surveillance interval. An excessive surveillance interval extension could reduce the margin of safety by reducing assurance that required equipment will function as designed; an overly restrictive surveillance interval could also reduce the margin of safety by imposing unnecessary testing wear, equipment manipulations, and system transients on the plant.
The existing requirements to perform cross-train testing were based on the operating experience available when they were added to the TS.
Typically this was done during the initial plant licensing in 1971.
The recently published Standard Technical Specifications (NUREG 1432) do not include cross-train testing requirements for the Engineered Safety Features components. It has been judged by the NRC and by the industry, that cross-train testing is un-necessary, and that testing at normal surveillance intervals is adequate to assure equipment operability. This recent judgement is based on a much larger accumulation of operating experience than was available at the time Palisades was licensed. There are no special features of the Palisades plant which would invalidate these more recent judgements of optimal testing requirements. Therefore, operation of the facility in accordance with the proposed changes will not involve a significant reduction in a margin of safety.
IV. Conclusion The Palisades Plant Review Committee has reviewed this Technical Specifications Change Request and has determined that proposing 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 Performance Assessment Department.
- ATTACHMENT 1 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 TECHNICAL SPECIFICATION CHANGE REQUEST REMOVAL OF CROSS TRAIN TESTING Replacement Proposed Pages
3.3 3.3.2 EMERGENCY ! COOLING SYSTEM (Cont'd]
- During power operation the requirements of 3.3.1 may be modified to allow one of the following conditions to be true at any one time. If the system is not restored to meet the requirements of 3.3.1 within the time period specified below, the reactor shall be placed in a hot shutdown condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. If the requirements of 3.3.1 are not met within an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the reactor shall be placed in a cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
- a. One safety injection tank may be inoperable for a period of no more than one hour.
- b. One low-pressure safety injection pump may be inoperable provided the pump is restored to operable status with i.n 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
- c. One high-pressure safety injection pump may be inoperable provided the pump is restored to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
- d. One shutdown heat exchanger and one component cooling water heat exchanger may be inoperable for a period of no more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
- e. Any valves, interlocks or piping directly associated with one of the above components and required to function during accident conditions shall be deemed to be part of that component and shall meet the same requirements as .listed for that component.
- f. Any valve, interlock or pipe associated with the safety injection and shutdown cooling system and which is not cover~d under 3.3.2e above but, which is required to function during accident conditions, may be inoperable for a period of no more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
3-29a Amendment No. 1-, l-
3.3 Basis (continued)
- ability to tolerate additional equipment failures. If it develops that (a) the inoperable component is not repaired within the specified allowable time period; or (b) a second component in the same or related system is found to be inoperable, the reactor will initially be put in the hot shutdown condition to provide for reduction of the decay heat from the fuel and consequent reduction of cooling requirements after a postulated loss-of-coolant accident. This will also permit improved access for repairs in some cases. After a limited time in hot shutdown if the malfunction(s) is not corrected, the reactor will be placed in the cold shutdown condition utilizing normal shutdown and cooldown procedures. In the cold shutdown condition release of fission products or damage of the fuel elements is not considered possible.
The plant operating procedures will require immediate action to effect repairs of an inoperable component and, therefore, in most cases, repairs will be completed in less than the specified allowable repair times. The limiting times to repair are intended to: (1) Assure that operability of the component will be restored promptly and yet, (2) allow sufficient time to effect repairs using safe and proper procedures.
The requirement for core cooling in case of a postulated loss-of-coolant accident while in the hot shutdown condition is significantly reduced below the requirements for a postulated loss-of-coolant accident during power operation. Putting the reactor in the hot shutdown condition reduces the consequences of a loss-of-coolant accident and also allows more free access to some of the engineered safeguards components in order to effect repairs.
Failure to complete repairs within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of going to the hot shutdown condition is considered indicative of a requirement for major maintenance and, therefore, in such a case, the reactor is to be put into the cold shutdown condition.
With respect to the core cooling function, there is functional redundancy over most of the range of break sizes. 1 ~
Adequate core cooling for the break spectrum up to and including the 42-inch double-ended break is assured with the minimum safety injection which is defined as follows: For the system of four passive safety injection tanks, the entire contents of one tank are assumed to be unavailable for emergency core cooling. In addition, of the two high-pressure safety injection pumps and the two low-pressure safety injection pumps, only one of each type is assumed to operate; and also that 25% of their combined discharge rate is lost from the primary coolant system out the break. The transient hot spot fuel clad temperatures for the break sizes considered are shown on FSAR Figures 14.17.9 to 14.17.13. These 3-32 Amendment No. -96, .J-1.+
3.4 CONTAINMEN~OLING Applicability
- Applies to the operating status of the containment cooling systems.
Objective To assure operability of equipment required to remove heat from the containment in normal operating and emergency situations.
Specifications Containment Cooling Systems 3.4.1 The reactor shall not be made critical, except for low-temperature physics tests, unless all the following conditions are met:
- a. The following equipment associated with diesel generator 1-2 is operable:
Containment Air Cooler VlA Contai~ment Air Cooler V2A Containment Air Cooler V3A Service Water Pump P7A Service Water Pump P7C Containment Spray Pump P54A Component Cooling Water Pump P528
- b. The following equipment associated with diesel generator 1-1 is operable:
Service Water Pump P78 Containment Spray Pump P548 Containment Spray Pump P54C Component Cooling Water Pump P52A Component Cooling Water Pump P52C
- c. All heat exchangers, valves, piping and interlocks associated with the above components and required to function during accident conditions are operable.
3.4.2 During power operation, one of the components listed in Specification 3.4.1 above may be inoperable for a period of up to seven days. If the inoperable component is not restored to operability within 7 days, the reactor shall be placed in a hot shutdown condition.
3-34 Amendment No. +/-94
3.4 CONTAINMENT CO~G (Cont'd)
- within 12 h-ours. If the inoperable component is not restored to operability within an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the reactor shall be pl aced in a cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
3.4.3 During power operation, the requirements of Specification 3.4.1 may be modified to allow a total of two of the components listed in Section 3.4.la or b to be inoperable at any one time for a period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If the operability of at least one of the two inoperable components is not restored within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the reactor shall be placed in a hot shutdown condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. If the operability of at least one of the two inoperable components is not restored within an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the reactor shall be placed in a cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Continued power operation with one component out of service shall be as specified in Section 3.4.2, with the permissible period in inoperability starting at the time that the first of the two components became inoperable.
3.4.4 Any valves, interlocks and piping directly associated with one of the above components and required to function during accident conditions shall be deemed to be part of that component and shall meet the same requirements as listed for that component.
3.4.5 Any valve, interlock or piping associated with the containment cooling system which is not covered under Specification 3.4.4 above and which is required to function during accident conditions may be inoperable for a period of no more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
3-35 Amendment No. 2-, !04
. ** - ...
- ATTACHMENT 2 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 TECHNICAL SPECIFICATION CHANGE REQUEST REMOVAL OF CROSS TRAIN TESTING Existing Pages Marked to Show Changes
3.3 EMERGENCY ~E COOLING SYSTEM (Cont'd) 3.3.2 During power operation the requirements of 3.3.1 may be modified to a1low one of the following conditions to be true at any one time. If the system is not restored to meet the requirements of 3.3.1 within the time period specified below, the reactor shall be placed in a hot shutdown condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. If the requirements of 3.3.1 are not met within an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the reactor shall be placed in a cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
a." One safety injection tank may be inoperable for a period of no more than one hour.
- b. One low-pressure safety injection pump may be inoperable provided the pump is restored to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The other 10*1 pressijre safety iAjeetioA pijmp shall be tested to demoAstrate operability prier to iAitiatiAg repair of the iAoperable pijmp.
- c. One high-pressure safety injection pump may be inoperable provided the pump is restored to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The other high pressijre safety iAjeetioA pijmp shall be tested to demoAstrate operability prior to iAitiatiAg repair of the iAopcrable pijmp.
- d. One shutdown heat exchanger and one component cooling water heat exchanger may be inoperable for a period of no more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
- e. Any valves, interlocks or piping directly associated with one of the above components and required to function during accident conditions shall be deemed to be part of that component and shall meet the same requirements as listed for that component.
- f. Any valve, interlock or pipe associated with the safety injection and shutdown cooling system and which is not covered under 3.3.2e above but, which is required to function during accident conditions, may be inoperable for a period of no more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Prier to iAitiatiAg repairs, all valves aAd iAterleeks iA the system that provide the dijplieate fijAetioA shall be tested to demoAstrate operability.
3-29a Amendment No. -2+, l
.* 3.3 EMERGENCY CORE,LING SYSTEM
- .
~/
Basis (continued) ability to tolerate additional equipment failures. Te pPe¥iae maximum assuPaAee that the PeauAaaAt eempeAeAt(s) will epePate if PequiPea te ae se, the PeauAaaAt eempeAeAt(s) is t~ he tested pPieP te iAittatiAg pepaiP ef the iAepePahl~ eempeAeAt. If it develops that (a) the inoperable component is not repaired within the specified allowable time period; -0r (b) a second component in the same or related system is found to be inoperable; the reactor will initially be put in the hot shutdown condition to provide for reduction of the decay heat from the fuel and consequent reduction of cooling requirements after a postulated loss-of-coolant accident. This will also permit improved access for repairs in some cases.* After a limited time in hot shutdown if the malfunction(s) is not corrected, the reactor will be placed in the cold shutdown condition utilizing normal shutdown and cooldown procedures. In the cold shutdown condition release of fission products or damage of the fuel elements is not considered possible.
The plant operating procedures will require immediate action to effect repairs of an inoperable component and, therefore, in most cases, repairs will be completed in less than the specified allowable repair times. The limiting times to repair are intended to: (1) Assure that operability of the component will be restored promptly and yet, (2) allow sufficient time to effect repairs using safe and proper procedures.
The requirement for core cooling in case of a postulated loss-of-coolant accident while in the hot shutdown condition is significantly reduced below the requirements for a postulated loss-~f-coolant accident during power operation. Putting the reactor in the hot shutdown condition reduces the consequences of a loss-of-coolant a~cident and also allows more free access to some of the engineered safeguards components in order to effect repairs.
Failure to complete repairs within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of going t~ the hot shutdown condition is considered indicative of a requirement for major maintenance and, therefore, in such a case, the reactor is to be put into the cold shutdown condition.
With respect to the core cooling function, there is functional redundancy over most of the range of break sizes. 121
- Adequate core cooling for the break spectrum up to and including the 42-inch double-ended break is assured with the minimum safety injection which is defined as follows: For the system of four passive safety injection tanks, the entire contents of one tank are assumed to be unavailable for emergency core cooling. In addition, of the two high-pressure safety _injection pumps and the two low-pressure safety injection pumps, only one of each type is assumed to operate; and also that 25% of their combined discharge rate is lost from the primary coolant system out the break. The transient hot spot fuel clad temperatures for the break sizes considered are shown on FSAR Figures 14.17.9 to 14.17.13. These 3-32 Amendment No. -96, -l-l-7
3.4 CONTAINMEN~OLING Applicability
- Applies to the operating status of the containment cooling systems.
Objective To assure operability of equipment required to remove heat from the containment in normal operating and emergency situations.
Specifications Containment Cooling Systems 3.4.1 The reactor shall not be made critical, except for low-temperature physics tests, unless all the following conditions are met:
- a. The following equipment associated with diesel generator 1-2 is operable:
Containment Air Cooler VIA Containment Air Cooler V2A Containment Air Cooler V3A Service Water Pump P7A Service Water Pump P7C Containment Spray Pump P54A Component Cooling Water Pump P52B
- b. The following equipment associated with diesel generator 1-1 is operable:
Service Water Pump P7B Containment Spray Pump P54B Containment Spray Pump P54C Component Cooling Water Pump P52A Component Cooling Water Pump P52C
- c. All heat exchangers, valves, piping and interlocks associated with the above components and required to function during accident conditions are operable.
3.4.2 During power operation, one of the components listed in Specification 3.4.1 above may be inoperable previaea that the cerrespeRaiRg reaijRaaRt cempeReRts shall be tested te acmeRstrate eperaeility for a period of up to seven days. If the inoperable component is not restored to operability within 7 days, the reactor shall be placed in a hot shutdown condition.
3-34 Amendment No. -l-G4
3.4 CONTAINMENT CO~NG (Cont'd)
- within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />; If the inoperable component is not restored to operability within an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the reactor shall be placed in a cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
3.4.3 During power operation, the requirements of Specification 3.4.1 may be modified to allow a total of two of the components listed in Section 3.4.la or b to be inoperable at any one time previded the emergeAcy diesel ceAAected te the eppesite eAgiAeered safeguards bus is started te demeAstrate eperability. The reduAdaAt cempeAeAt er system eA the ether bus shall be tested befere iAitiatiAg maiAteAaAce eA the iAeperable cempeAeAts for a period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If the operability of at least one of the two inoperable components is not restored within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the reactor shall be placed in a hot shutdown condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. If the operability of at least one of the two inoperable components is not restored within an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the reactor shall be placed in a cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Continued power operation with one component out of service shall be as specified in Section 3.4.2, with the permissible period in inoperability starting at the time that the first of the two components became inoperable.
3.4.4 Any valves, interlocks and piping directly associated with one of the above components and required to function during accident conditions shall be deemed to be part of that component and shall meet the same requirements as listed for that component.
3.4.5 Any valve, interlock or piping associated with the containment cooling system which is not covered under Specification 3.4.4 above and which is required to function during accident conditions may be inoperable for a period of no more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> previded that prier te iAitiatiAg repairs, all valves aAd iAterlecks iA the system that previde the duplicate fuActieA shall be tested te demeAstrate eperability.
3-35 Amendment No. 2-, lG4