ML18052B051

Technical Evaluation Rept for Palisades Plant,Response to NRR Generic Ltr 83-37, Interim Informal Rept

ML18052B051
Person / Time
Site:	Palisades
Issue date:	03/30/1987
From:	Mobley E EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML18052B050	List: ML18052B049 ML18052B051
References
CON-FIN-D-6022, RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.1, TASK-2.B.3, TASK-2.E.1.1, TASK-2.F.1, TASK-2.F.2, TASK-3.D.3.4, TASK-TM EGG-NTA-7484, GL-83-37, TAC-54555, NUDOCS 8706050255
Download: ML18052B051 (26)

Text

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EGG-NTA-7484 March 1987 INFORMAL REPORT ct.I Idaho National Engineering . TECHNICAL EVALUATION REPORT FOR THE PALISADES PLANT, RESPONSE TO NRR GENERIC LETTER 83-37

• Laboratory Managed by the US.

EJepartment E. V. Mobley of Energy

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.~ ~.:) EGC.13 Idaho Work performed under Prepared for the DOE Contract No. DE-AC07-761001570 U.S. NUCLEAR REGULATORY COMMISSION 8706050255 870330 \ \

PDR ADOCK 0500025.5\ .\

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DISCLAIMER This book was prepared as an account of work sponsored by an agency of the United States*Government. Neither the United States Government nor any agency thereof.

nor any of their employees, makes any warranty, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product or process disclosed, or represents that its use would not infringe privately owned rights. References herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise, does not necessarily constitute or imply its endorsement, recommendation, *or favoring by the United States Government or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of the United States Government or any agency thereof.

EGG-NTA-7484

• - TECHNICAL EVALUATION REPORT OF THE PALISADES PLANT RESPONSE TO THE U.S. NUCLEAR REGULATORY COMMISSION, OFFICE OF NUCLEAR REACTOR REGULATION'S GENERIC LETTER NO. 83-37 Docket No. 50-255 E. V. Mobley Published March 1987 Idaho National Engineering Laboratory EG&G Idaho, Inc.

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Prepared fcrr the U.S. Nuclear Regulatory Conunission Washington, O.C. 20555 Under DOE Contract No. DE-AC07-76ID01570 FIN No. 06022

CONTENTS ABSTRACT iii FOREWORD iii

1. INTRODUCTION ............................................... : .... . 1 '-"

2. DISCUSSION AND EVALUATION ..................................*..... 2 2.1 Reactor Coolant System Vents (II.B.1) ........... : ......... . 2

.2.2 Postaccident Sampling (II.8.3) ............................ . 3 2.3 Long Term Auxiliary Feedwater System Eva 1ua ti on ( I I . E. 1 . 1 ) ......*............................... 3 2.4. Noble Gas Effluent Monitors (II.f .1.1) .................... . 4 2.5 Sampling and Analysis of Plant Effluents (II.F.1.2) 5 2.6 Containment High-Range Radiation Monitor (II.F.1.3) 6 2.7 Containment Pressure Monitor (II.F.1.4) .............*...... 7 2.8 Containment Water Level Monitor (II.F.1.5) ................ . 7 2.9 Containment Hydrogen Monitor (II.F.1.6) ................... . 8 2.10 Instrumentation for D~tection of Inadequate Core Cooling (II .F .2) .......* *.............................. . 9 2.11 Control Room Habitability Requirements (III.D.3.4) *:******* 10

3. ADDITIONAL INFORMATION NEEDED TO COMPLETE THE REVIEW ............ . 16

4.

SUMMARY

.............. ; .......................................... . 18

5. REFEREN.CES ........................* .............................*. 19 ii

v ABSTRACT

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this EG&G Idaho, Inc., report evaluates the sub~itlals prov,ded by Consumers Power Company for the Palisades Plant. The submittals are ,n response to Generic Letter No. 83-37, uNUREG-0737 Technical Spec,f,cations (TS)". Applicable sections of the Technical Specifications are evaluated to determine compliance to the guidelines established in the Generic Letter.

FOREWORD This report is supplied as part of the "Technical Assistance for Operating Reactors Licensing Actions" being conducted for the U.S. Nuclear Regulatory Commission, Washington D.C., by EG&G Idaho, Inc., NRR and I&E Support.

The U.S. Nuclear Regulatory Commission funded the work under authorization B&R 20-19-10-11 1, FIN No. D6022.

Docket No. 50-255 TAC No. 54555

TECHNICAL EVALUATION REPORT PALISADES PLANT

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1. INTRODUCTION On November 1, 1983, a letter was sent by the Director, Divis1on of Licensing, "To All Pressurized Water Reactor Licensees." This Generic 1

Letter 83-37 provided NRC Staff guidance on the content of the Technical 2

Specifications (TS) associated with certain items in NUREG-0737. The 1 .

responses to Generic Letter 83-37 filed to date by the Consumers Power Company for the Palisades Plant include (a) Technical Specification Change 3

Request (TSCR) dated August 30, 1982, (b) Information dated 4 . 5 .

October 19, 1982, (c) TSCR dated November 5, 1982, placed on hold by 6 7 letter dated March 5, 1986, (d) TSCR dated July 9, 1984, (e) TSCR 8 .9 dated July 31, 1984, modified by TSCR dated October 25, 1984~

10 .

(f) TSCR dated September 17, 1984, supplemented by TSCRs dated 11 12 13 May 31, 1985, June 21, 1985, and October 28, 1985, (g) TSCR 14 15 dated November 19, 1984, revised by TSCR dated February 28, 1986, 16 and (h) TSCR dated November 21, 1985. The following report provides the evaluation of the CPC submittals and indicates information and act1on required for resolving the remaining issues.

1

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2. DISCUSSION ANO EVALUATION The l\censee was requested to prov\de Techn1cal Spec1f1cat1ons for several d\fferent systems. Each of these proposals 1s d1fcussed and evaluated \n an \nd1vidual su~section below.

2.1 Reactor Coolant System Vents (II.B.l) 1 The Generic letters* contains the following statement:

"At least o~e reactor coolant system vent path (cons1st1ng of at least two valves *1n series which are powered from emergency buses) shall be o~erable and closed at all times (except for cold *,

shutdown and refueling) at each of the following locations:

a. Reactor Vessel Head

b. Pressur1zer steam space.

c. Reactor coolant system high point "A typical Technical Specification for reactor coolant system vents is provided \n Enclosure 3. For the plants using a power operated rel\ef valve (PORV) as a reactor coolant system vent, the.block valve is not required to be closed if the PORV is operable."

Evaluation

)

3

• The Licensee has proposed the addition of Technical Specification Section 3.1.9 and revision of Table 4.2.2.

This item is b~ing reviewed by the NRC Staff and no further evaluat1on 1s being performed.as.part of th1s report.

2

f' 2.2 Postacc1dent Sampl1ng (II.B.3) l The Gener1c Letter conta1ns the follow1ng statement:

"Ltcensees should ensure that the1r plant has the capab111ty to obta1n and analyze reactor coolant and conta1nment atmosphere samples under acc1dent cond1t1ons. An adm1n1strat1ve program should be establ1shed, implemented and ma1ntained to ensure this capability. The program should include:

a) training of personnel b) procedures for sampl1ng and analysis, and c) provisions for maintenance of sampling and analysis equipment "It is acceptable to the Staff, if the licensee elects to reference this program in the administrative controls sect1on of the Techn1cal Spec1fications and include a detailed description of the program in the plant operation manuals. A copy of the program should be easily available to the operating staff during accident and trans1ent conditions."

• A model Technical Spec1fication for postaccident sampling is l

provided that requires the capability to sample and analyze radioact1ve iodines and particulates 1n plant gaseous effluents.

Evaluation 7

The Licensee proposed the addition, in letter dated July 9, 1984, of Technical Specif1cation Section 6.17.

This item is be1ng reviewed by the NRC Staff and no further evaluation is being performed as part of this report.

2.3 Long Term Auxiliary feedwater System Evaluat1on (II.E.1.1) 1 The Generic Letter contains the following statement:

"The objective of this item 1s to 1mprove the reliabil1ty and performance of the auxi 11ary feedwater (AfW) system. Technical Spec1ficat1ons depend on the results of the licensee's evaluation and staff review of each plant. The 11mit1ng conditions of 3

I operatton (LCO) and survetllance requtrements for the AFW s~stem should be stmtlar to safety-related systems. Typtcal genertc Techntcal Spectftcattons are provtded tn Enclosure 3. These spectftcattons are for a plant whtch has three auxtliary feedwater pumps. Plant spectftc Technical Spectftcattons could be establtshed by ustng the genertc Techntcal Spectftcattons for the AFW system. 11 Eva luat ton 0

10 The Ltcensee proposed changes, tn letters dated September 17, 1984, 11 12 13 May 31, 1985, June 21, 1985, and October 28, 1985, tn Techn1cal Spectfications Secttons 3.3, Emergency Core Coo11ng System; 3.5, Steam and Feedwater Systems; 4.6, Safety Injectton and Containment Spray System Tests; 4.9, Auxtliary Feedwater System; and Tables 3.17.4 and 4.1.3. The 10-13 '

four Ltcensee submittals were revtewed by the NRC Staff and found 17 acceptable. The Safety Evaluatton ts enclosed with the nottficatton of 17 tssue of Amendment No. 96.

1 Item II.E.1.1 of the Generic Letter ts closed.

2.4 Noble Gas Effluent Monitors (II.F.1.1) 1 '

The Generic Letter contatns the following statement:

11 Noble gas effluent monHors provtde information, during and following a~ acctdent, wh1ch are constdered helpful to the operator in accessing the plant conditton. It ts desired that these monttors be operable at all ttmes durtng plant operatton, but they are not required fo~ safe shutdown of the plant. In case of failure of the monttor~ approprtate acttons should be taken to restore 1ts operattonal capability 1n a reasonable pertod of ttme. Cons1dertng the 1mportance of the availability of the equtpment and possible delays 1nvolved 1n administrative controls, 7 days ts considered to be the appropriate ttme period to restore the operability of the monttor. An alternate method for monHoring the effluent. should be inHtated as soon as practical, but no later than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the tdenttftcatton of the fatlure of the monttor. If the monitor ts not restored to operable condtttons wtthtn 7 days after the fatlure a spectal report should be submttted to the NRC wtthtn 14 days following the event, outlintng the cause of inoperabtlity, acttons taken and the planned schedule for restoring the system to operable st'atus. 11 4

A model Techn1cal Spec1f1cat1on for noble gas effluent mon1tors 1s l

also prov1ded that spec1f1es mon1tor locat1ons and measurement ranges.

Evaluat1on 5

The L\censee proposed changes, 1n letter dated November 5, 1982, 1n Techn\cal Spec\fications Table 4.1.2 and replacement of Tables 3.17.4 and 4.1.3. These proposed changes were placed on hold, pend\ng revis1ons, by 6

L1censee letter dated March 5, 1986. A revis1on to Table 3.24.2 was 9

proposed 1n letter dated October 25, 1984. See ~lso Sect1on 3 of th1s report.

Rev\sion and resubmittal of the November 5, 1982, Techn\cal Spec\ficat\ons change request for Item 11.F.1.l \s required to meet the 1

Generic Letter.

2.5 Sampl1ng and Analysis of Plant Effl~ents (II.F.1.2) 1 The Generic Letter contains the following statement:

"Each operat1ng nuclear power reactor should have the capabil1ty to collect and analyze or measure representative samples of rad1oactive iodines and particulates in plant gaseous effluents dur1ng and following an accident. An administrative program should be establ1shed, \mplemented and ma1nta1ned to ensure this capab111ty. The pr~gram should \nclude:

a) tra1n\ng of personnel b) procedures for sampling and analysis, and c) provtsions for ma\ntenance of sampling and analys1s equ1pment "It is acceptable to the staff, if the licensee elects to reference this program \n the ~dm\nistrat\ve controls sect1on of the Technical Specificat1ons and include a detailed descr1ption of the program in the plant operation manuals. A copy of the program should be readily available to the operating staff during accident and transient conditions."

A model Technical Spec\f\cation for postaccident sampling \s

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provided_ that requires the capabil\ty to sample and analyze rad1oactive iodines and particulates in plant gaseous effluents.

5

.,.

Evaluation 5

The licensee proposed changes, in letter dated November 5, 1982, in Technical Specifications Table 4.1.2 and replacement of Tables 3.17.4 5

and 4.1.3. The requested changes were modified by letter dated 8 5 July 31, 1984. These proposed changes were placed on hold, pending 6

revisions, by licensee letter dated March 5, 1986. See also Section 3 of this report.

Revision and resubmHtal of the November 5, 1982, Technical Specifications change request for Item II.F.1.1 is required to meet the 1

Generic letter.

2.6 Containment High-Range Radiation Monitor (II.f .1.3) 1 The Generic letter contains the following statement:

"A minimum of two in containment radiation-level monitors wi.th a maximum range of 108 rad/hr (107 R/hr for photon only) should be operable at all times except for cold shutdown and refueling outages. In case of failure of the monitor, appropriate actions should be taken to restore its operational capability as soon as possible. If the monitor is not restored to operable condition within 7 days after the failure, a special report should be submitted to the NRC within 14 days.following the event, outlining the cause of inoperability, actions taken and the planned schedule for restoring the equipment to operable status.

"Typical surveillance requirements are shown in Enclosure 3. The setpoint for the high radiation level alarm should be determined such that spurious alarms will be precluded. Note that. the.

acceptable calibration techniques for these monitors are discussed in NUREG-0737."

Evaluation 5

The licensee proposed changes, in letter dated November 5, 1982, in Technical Specifications Table 4.1.2 and replacement of Tables 3.17.4 and 4.1.3. These proposed changes were placed on hold, pending revisions,

- 6 by licensee letter dated March 5, 1986. See also Section 3 of this report'>.

Rev\s\on and resubm\ttal of the November 5, 1982, Techn\cal Spec\f\cat\ons change request for Item II.f.1.3 \s requ\red for compl\ance l

w\th the Gener\c Letter.

2.7 Conta\nment Pressure Hon\tor (II.f .1.4) l The Gener1c Letter conta\ns the follow\ng statement:

11 Conta\nment pressure should be cont\nuously 1nd1cated \n the control room of each operat\ng reactor dur\ng Power Operat\on, Startup and Hot .Standby modes of operat\on. Two channels should be operable at all t\mes when the reactor \s operat\ng \n any of the above ment\oned modes. Techn\cal Spec1f1cat\ons for these mon\tors should be \ncluded w1th other acc\dent mon\tor\ng 1nstrumentat1on 1n the present Techn1cal Spec1f1cat1ons.

L\m1t\ng cond1t1ons for operat1on (1nclud1ng the requ1red Act1ons) for the conta1nment pressure mon1tor should be s1m11ar to other act\dent monHor\ng \nstrumentat\on \ncluded 1n the present Techn\cal Spec\f1cat\ons. Typ1cal acceptable LCO and surve\-~lance requ\rements for a~c1dent mon1tor\ng 1nstrumentat1on are \ncluded \n Enclosure 3."

Evaluat \on 5

The pr.oposed Techn\cal SpecH\cat\ons \nclude rev\sed Tables 3.17 .4, 1

4.1.2, and 4.1.3 that apply to Item II.f .1.4 of the Gener1c Letter.

Th\s 1tem \s be\ng rev1ewed by the NRC Staff and no further evaluat\on 1s be\ng performed as part of th1s report.

2.8 Conta\nment Water Level Mon\tor (II.f .1.5)

"

1 The Gener1c Letter conta1ns the follow1ng statement:

.. "A cont1nuous \nd\cat\on of conta\nment water level should be prov\ded \n the control room of each reactor dur\ng Power Operat1on, Startup and Hot Standby modes of operat\on. At least one channel for narrow range and two channels for w1de range 1nstruments should be operable at all t\mes when the reactor \s operat\ng \n any of the above modes. Narrow range \nstruments should cover the range from the bottom to the top of the 7

y conta1nment sump. W1de range 1nstruments should cover the range~

from the bottom of the conta1nment to the elevat1on equ1valent to a 600,000 gallon (or less 1f just1f1ed) capac1ty.

"Techn1cal Spec1f1cat1ons for conta1nment water level mon1tors should be 1ncluded w1th other acc1dent mon1tor1ng 1nstrumentat1on 1n the present Techn1cal Spec1f1cat1ons. LCOs (1nclud1ng the requ1red Act1ons) for w1de range mon1tors should be s1m11ar to other acc1dent mon1tor1ng 1nstrumentat1on 1ncluded 1n the present Techn1cal Spec1f1cat1ons. LCOs for narrow range mon1tor should 1nclude the requ1rement that the inoperable channel w111 be restored to operable status w1th1n 30 days or the plant w111 be brought to Hot Shutdown cond1t1on as requ1red for other acc1dent mon1tor1ng 1nstrumentat1on. Typ1cal acceptable LCO and surve1llance requ1rements for acc1dent m~n1tor1ng 1nstrumentat1on are included in Enclosure 3."

Evaluat1on

. 5 The proposed Techn1cal Spec1f1cat1ons 1nclude revised Tables 3.17.4

. ' 1 and 4.1.3 that apply to Item II.f;l.5 of the Gener1c Letter**.

Th1s 1tem 1s be1ng rev1ewed by the NRC Staff and no further evaluat1on 1s being performed as part of th1s report.

2.9 Conta1nment Hydrogen Mon1tor' (II.F.1.6) 1 The Generic Letter contains the follow1ng statement:

"Two 1ndependent conta1nment hydrogen mon1tors should be operable at all t1mes when the reactor 1s operat1ng 1n Power Operat1on or Startup modes. LCO for these mon1tors should 1nclude the requ1rement that w1th one hydrogen mon1tor inoperable, the mon1tor should be restored to operable status w1th1n 30 days or the plant should be brought to at least a hot standby'cond1t1on w1th1n the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. If both mon1tors are 1noperable, at least one mon1tor should be restored to operable status w1thin 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the plant should be brought to at least hot standby condit1on w1thin the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Typical surve111ance ,

requ1rements are provided in Enclosure 3."

8

Evaluation 5

The Licensee proposed changes, in letter dated November 5, 1962, in Technical Specifications Table 4.1.2 and replacement of Tables 3.17.4 and 4.1.3. These proposed changes were placed on hold, pending revisions, 6

by Licensee letter dated March 5, 1966. See also Section 3 of this report.

Revision and resubm1ttal of the November 5, 1982, Technical Specifications change request for Item II.F.1.6 is required to meet the 1

Generic Letter.

2.10 Instrumentation for Detection of Inadequate Core Cooling (II.F.2)

' l The Generic Letter contains the following statement:

11 Subcooling margin mon1tors, core ex1t thermocouples, and a reactor coolant inventory tracking sytem (e.g., differential pressure measurement system designed by Westinghouse, Heated Junction Thermocouple Sy~tem designed by Combustion Engineering, etc.) may be used to provide indication of the approach to, existence of, and recovery from inadequate core cooling (ICC). These instrumentation should be operable during Power Operation, Startup, and Hot Shutdown modes of operation for each reactor.

11 Subcooling margin mon1tors should have already been included in the present Technical Specifications. Technical Specifications for core exit thermocouples and the-reactor coolant inventory tracking system should be included w1th other accide.nt mon1toring instrumentation in the present Technical Specifications.* Four core-exit thermocouples in each core quadrant and two channels in the reactor coolant tracking system are required to be operable when the reactor is operating in any of the above mentioned modes. Minimum of two core-exit thermocouples in each quadrant and one channel in the reactor coolant tracking system should be operable at all times when the reactor is operating in any of the above mentioned modes. Typical acceptable LCO and surveillance requirements for accident monitoring instrumentation are provided in Enclosure 3. 11

• 9

Evaluation 16 The Licensee proposed changes, 1n letter dated November 21, 1985, to Technical Specifications* Tables 3.17 .4 and 4.1.3.

This item is being reviewed by the NRC Staff and no further evaluation is being performed as part of this report.

2.11 Control Room Habitability Requirements (1II.D.3.4) 1 The Generic letter contains the following statement:

"licensees should assure that control room operators will be adequately protected against the effects of the accidental .

release of toxic and/or radioactive gases and that the nuclear power plant can be safely operated or shutdown under design basis accident conditions. If the results of the analyses of postulated accidental.release of toxic gases (at or near the plant) indicate any need for installing the toxic gas detection

~ystem, it should be included in*the Technical Specifications.

Typical acceptable lCO and surveillance requirements for such a detection system (e.g. chlorine ~etection system) are provided in Enclosure 3. All detection systems should be included in the Technical Specifications.

"In addition tri the above requirements, other aspects of the control room habitability requirements should be included in the Technical Specifications for the control room emergency air cleanup system. Two independent control room emergency air cleanup systems should be operable continuously during all modes of plant operation and capable of meeting design requirements.

Sample Technical Specifications are provided in Enclosure 3."

Evaluation 4

The Licensee. letter dated October 19, 1982, includes an analysis to show that an offsite chlorine release would not result in exceeding 4

toxicity limits in the control room. It is also shown that for the cooling tower treatment chemicals used, no onsite chlorine evaluation is 1

required. No Chlorine Detection Specification is required. The system 18 was accepted by the NRC Staff by the SER transmitted on April 29, 1983.

10

14 The Licensee proposed changes, in letter dated November 19, 1984, 14 in a number of Technical Specifications Sections. The Sections which pertain to Control Room Habitability are 3.14, Control Room Emergency Air Cleanup System, Limiting Conditions for Operation and Part l of Table 4.2.3, HEPA Filter and Charcoal Adsorber Systems, Control Room 14 Emergency Air Cleanup System. In the PaJisades proposed changes Part 1 of Table 4.2.2 comprises the Surveillance Requirements for LCO 14 Specification 3.14. Together, the*Palisades LCO 3.14 plus Part l of 14 Table 4.2.3 correspond to the Generic Letter model 3/4.7.7, Control 14 Room Emergency Air Cleanup System. The November 19, 1984 , proposal

. 1 differs from the Generic Letter as follows:

l4 2.11.l. The Licensee Limiting Condition for Operation (LCO) 3.14.l includes system details a. through d. that are not in the Generic 1

Letter.

..

14 Details a. through d. of the LC0 provide clarification and are judged acceptable.

14 2.11.2. The Licensee LCO uses names instead of numbers for mode designation.

14 The-mode names used by the Licensee are equivalent to the mode l

numbers in the Generic Letter and are judged acceptable.

14 2.11.3. The Licensee Action, LCO 3.14.1, for modes above cold shutdown reads, * *

• be in at least hot shutdown within the next 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, 11 1

and in cold shutdown within the following 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. 11 The Generic Letter model reads, 11 * *

• be in at least hot standby within the next i hours and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. 11 The mode required by the 14 Licensee is lower, but times are longer, than those shown in the 1

. Generic Letter model.* Additional information is required to establ1sh the degree of equivalence for the compensating effects of mode and time.*

14 The rationale for the mode and times in the Action for conditions 1

abova cold shutdown i1 required to meet the Generic Letter.

11

'*

14 2.11.4. The L1censee Act1ons a. and b~ LCO 3.14.1. for cold shutdown and refue11ng cond1t1ons do not 1nclude the prov1s1ons, as 1n the 1

Gener1c Letter model, for operat1on of the Control Room Emergency Air Cleanup System in recirculat1on and continuat1on of some reactor core operations.

14 From the standpoint of safety, the licensee Action for cold shutdown and refueling is conservative and is judged a-cceptable~

. . 14 2.11.5. The licensee Surveillance~Requirement (SR), Table 4.2.3 Item 1.a, uses less than or equal to 90°F, not 80°F as 1n the Generic 1

Letter model, for the control room temperature that ver1f1es the emergency a1r cleanup*system operabi11ty. Although a control room approach1ng 90°F would be edg1ng out of the comfort zone on charts commonly used for a1r cond1t1on1ng system des1gn, up to 90°F can reasonably be def1ned as hab1table for some specif1c purposes.

The value of less than or equal to 90°F to ver1fy. Control Room Emergency A1r Cleanup System operab111ty is judged acceptable.

14 2.11.6. The Licensee SR, Table 4.2.3 Item 1.b, does not include 1

the phrase "on a staggered test bas1s" 11ke the Gener1c Letter model, and the first sentence under Item 1 reads, "The co*ntrol Room ... system ... ,"

1 not "Each control room ... system ... " The Gener1c Letter model requirement for testing of each system on a staggered basis prov1des the desired degree of assurance that the Control Room Emergency A1r Cleanup System funct1on w111 be achieved.

ClarH1catfon:'"that both -systems are to be tested *and justHlcat1on for I

om1ssion of the staggered test basis are required to meet the Generic 1

Letter.

12

14 2.11.7. The L1censee SRs, Table 4.2.3 Items l.c. and l.e. state~

"once per refuel1ng cycle," 1nstead of "once per 18 months," as 1n the 1

Gener1c Letter model, for the max1mum 1nterval for several operab111ty verif1cat1on tests. The extremes, or mean and dev1at1on, or some other measure of refuel1ng cycle length 1s needed to establ1sh the degree to

. 1 which the intent of the Generic Letter is met.

Just1ficat1on for the use of refueling cycle instead ~f 18 months for the test interval in Table 4.2.3 Items l.c. and l.e. is requ1red to meet 1

the Generic Letter.

14 2.11.8. The Licensee SR, Table 4.2.3 Item l.c. states the interval for verification of operab11Hy test as: "At least once per ... or (1) after ... maintenance ... or (2) following ... painting ... " The Generic 1

letter model also uses or,. but 1n the corresponding parts of Regulatory Guide 1.52 and is used. The use of and is preferable because or could be read as being an alternate to the bas1c testing 1nterval.

Clarification of the testing interval is required to meet the Generic Letter ..1 -

14 2.11.9. The Licensee SR, Table 4.2.3 Item l.c., requ1res an operability test after major painting. A criterion, procedure, or other documented method.for decid1ng how much pa1nting warrants a test is needed by plant personnel.

Information on the availab111ty to plant personnel of a method for determining of how much painting warrants a system test is requ1red to meet 1

the Generic letter.*

14 2.11.10. The Licensee SR, Table 4.2.3, does not include a 1

requirement fo~ a bypass flow test, as in the Gener1c Letter model, that applies to systems with d1vert1ng valves.

13

Conf1rmat1on that .the system does not have d1vert\ng valves. or other just1f1cat1on for om1ss1on of the bypass flow test. 1s requ1red to meet the 1

Gener1c Letter.

14 2.11.11. The L1censee SR. Table 4.2.3 Item 1.e.1., 1 allows 8 1n.

water gauge. not 6 1n. water gauge 11ke the Gener1c Letter model. for the max1mum pressure drop access the comb1ned f1lters.

The reasons for spec1fy1ng 8 1n. water gauge for comb1ned f11ter 1

pressure:drop are requ1red to meet the Gener1c Letter.

14 2.11.12. The L1censee SR. Table 4.2.3 Item l.e.2. does not 1

1nclude the Phase A des1gn~t1on. like the Gener1c Letter model.

preceding the isolat1on test s1gnal.

The reasons for om1ss1on of the Phase A des1gnat1on 1s requ1red to 1

meet the Gener1c Letter.

14 2.11.13.* A rev1s1on to the proposed Section 3.14 was requested 1n 15 15*

L1censee letter dated February 28. 1986. The change requested 1s for Act1-0ns that would reduce operab1lity requ1rements for the Control Room Emergency A1r Cleanup System (CREACS) under condit1ons in wh1ch conta1nment 1ntegr1ty 1s not required. One argument presented by the L1censee 1s based pr1mar1ly on the low probab11Hy of a fuel handHng or boron d1lut1on 1

1nc1dent. The Gener1c Letter states that two systems should be operable cont1nuously dur1ng all modes and. 1n add1t1on. control room hab1tab111ty requ1rements are spec1fically not 11m1ted to rad1oact1vity releases. The 1

Gener1c Letter requ1rement 1ncludes any tox1c gas. such as smoke. The analyse~ perta1n1ng only to conta1nment 1ntegr1ty do not adequately support

. 1 a reduct1on 1n the CREACS Act1on requ1rements 1n the Gener1c Letter 15 Another argument presented by the L1censee 1s that 1f ,conta1nment .-

1ntegrity is not requ1red. control room hab1tab111ty requirements should not apply because only spec1f 1c react1v1ty-related operat1ons w1th low acc1dent potent1al are allowed. Even though the acc1dent potential may be 14

low, the proposed Techn1cal Spec1f1cat1ons appear to allow a react1v1ty-related operat1on to start or cont1nue when the control room 1s not hab1table and are therefore judged not acceptable.

1 Further just1f1cat1on 1s requ1red to meet the Gener1c Letter.

15

v

3. ADDITIONAL INFORMATION NEEDED TO COMPLETE THE REVIEW In Section 2, "Discussion and Evaluation," it is shown that to meet l

the Generic Letter, addit\onal information from or action by the licensee is required for some items. Following is a compilation of the needed information or action.

o Noble Gas Effluent MonHors (Il.F .. l.l.)

o Sampling and Analys\s of Plant Effluents (II.F.1.2) o Containment High-Range Radiation Monitor (II.F.l.3) o Conta\nment Hydrogen Mon\tor (II.F.1.6).

6 These \terns are on hold pend\ng rev\sions, per L\censee request.

Prov\de the revised Technical Specifications.

o Control Room Habitability Requirements (III.D.3.4).

See also Item 2.11.3. Provide a change request to the

. l Technical Specifications to *conform to the Generic Letter or provide acceptable rationale for the modes and associated times in the Action for conditions above cold shutdown, 14 LCO 3.14.l.

See also Item 2.11.6. Provide a change request to the l

Technical Specificat\ons to conform to the Generic Letter or provide clarification to indicate that both systems are 14 to be tested, Table 4.2.3. Item l.

See also Item 2.11.6. Provide a change request to the l  ::.

Technical Specifications to conform to the Generic Letter or provide justification for not requiring tests on a

. 14 staggered basis, Table 4.2.3 Item 1.6.

16

See also Item 2.11.7. Provide a change request to the 1

Technical Specifications to conform to the Generic Letter or provide justification for use of refueling cycle instead of 18 months for the test interval, Table 4.2.3 Items 1.c 14 and l.e.

See also Item 2.11.8. Provide clarification to indicate what, in any event, is the longest test interval,

' 14 Table 4.2.3 Item l.c.

See also Item 2.11.9. Provide information on the method for determination of how much painting warrants a system test, Table 4.2.3 Item l.c.

See also Item 2.11.10. Provide one of the following:

Confirmation that the system does not have diverting valves, or justification for omission of the bypass flow test. See.

l Generic Letter model SR 4.7.7.c.l.

See also Item 2.11.11. Provide the reasons for specifying 14 8 in. water gauge pressure drop, Table 4.2.3 Item l.c.l.

See also Item 2.11.12. Provide the reasons for omission of

. 14 the Phase A designation, Table 4.2.3. Item l.e.2.

See also Item 2.11.13. Withdraw the Action change 15 request or provide additional justification frir the 15 Action change request.

r 17

y

4.

SUMMARY

The following item is considered to be consistent with the Generic 1

Letter:

0 Long Term Auxiliary Feedwater System Evaluation (11.E.l.l).

The following Hem differs from the Generic Letter.,:."-~

o Control Room Habitability Requirements (111.D.3.4).

The following items will be reviewed by the NRC Staff:

o Reactor Coolant System Vents (11.B.l) o Postaccident Sampling (11.B.3) o Noble Gas Effluent Mo'nHors ( 11.F .1.1) o S~mpling and Analysis of Plant Effluents (11.F.l.2) o Containment High-Range Radiation Monitor (11.F.l.3) o Containment Pressure Monitor (11.F.l.4) o Containment Water Level Monitor (11.F.l.5) o Containment Hydrogen Monitor (11.F.l.6) o l.nstrumentation for Detection of Inadequate Core 'cooling (11.F.2.}.

18

5. REFERENCES

1. D~G. Eisenhut, NRC letter, To All Pressurized Power Reactor l1censees, "NUREG-0737 Techn1cal Specificat1ons (Gener1c letter 83-37),"

November 1, 1983.

2. NUREG-0737, Clarification of TMI Action Plan Requirements, published by the Division of licensing, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commiss1on, November 1980.

3. David J. VandeWalle letter to Dennis H. Crutchfield, "Docket 50-255 -

license DPR Palisades Plant - Proposed Techn1cal Spec1f1cat1on Change Request - Primary Coolant System (PCS) Gas Vent System,u Consumers Power Company, August 30, 1982.

4. Br1an D. Johnson letter to Denn1s H. Crutchf1eld, "Docket 50-255 -

license DPR Pal1sades Plant - NUREG-0737, Item 111.D.3.4,"

Consumers Power Company, October 19, 1982.

5. Dav1d J. VandeWalle letter to Dennis H. Crutchfield, "Docket 50-255 -

license DPR Pal1sades Plant - Proposed Techn1cal Spec1fication Change Request - NUREG-0737, Items 11.f.1.1, 11.f.1.2, 11.f.l.3, and 11.f.1.6," Consumers Power Company, November 5, 1982.

6. James L. Kuem1n letter to Director, Nuclear Reactor Regulat1on, "Docket 50-255 - L1cense DPR Palisades Plant - Backlog of Techn1cal Spec1f1cat1on Change Requests," Consumers Power Company, March 5, 1986.

7. Brian D. Johnson letter to Dennis H. Crutchf1eld, "Docket 50-255 -

License DPR Palisades Plant - Proposed Technical Specification Change Request Post-Accident Sampl1ng," Consumers Power Company, July 9, 1984. *

8. David L. Vandewalle letter to Dennis H. Crutchf1eld, "Docket 50-255 -

License DPR-20 ~Palisades Plant - Radiological Effluent Technical Specifications (RETS). Offsite Dose Calculation Manual (ODCH) and Process Control Program (PCP), 11 Consumers Power Company, July 31, 1984.

9. David L. VandeWalle letter to Director, Nuclear Reactor Regulation, "Docket 50-255 - L1cense DPR Palisades Plant - Technical Specification Change Requests Modification Radiological Effluent Technical Specifications (RETS), 11 Consumers Power Company, October 25, 1984.

r 10. David VandeWalle letter to Director, Nuclear Reactor Regulation "Docket 50-255 - License DPR Palisades Plant - Proposed Technical Spec1fication Change Request - Auxiliary feedwater System, 11 Consumers Power Company, September 17, 1984.

11. Thomas C. Bord1ne letter to D1rector, Nuclear Reactor Regulat1on, "Docket-50-255 - l1cense DPR Palisades Plant - Proposed Techn1cal Specification Change Request - Auxi11ary Feedwater System Pump D1scharge Valve~. Consumers Power Company, May 31, 1985.

11 19

12. Thomas C. Bord\ne letter to D\rector, Nuclear Reactor Regulat\on, "Docket 50-255 - l\cense DPR Pal\sades Plant - Add\t\onal lnformat\on - AFW System Techn1cal Spec\f\cat1on Change Request,"

Consumers Power Company, June 21, 1985.

13. Kenneth W. Berry .letter to D1rector, Nuclear Reactor Regulat1on, "Docket 50-255 - l1cense DPR~20 - Pal1sades Plant - Consol1dat1on of Prev1ous Techn1cal Spec\f1cat1on Change Request," Consumers Power Company, October 28, 1985.

14. Dav\d J. VandeWalle letter to D1rector, Nuclear Reactor Regulat1on, "Docket 50-255 - l\cense DPR-~O ~ Pal1sades Plant - Proposed Techn1cal Spec\fication Change Request - Control Room Hab1tab111ty," Consumers Power Company, November 19, 1984.

15. Kenneth W. Berry letter to D1rector, Nuclear Reactor Regulation, "Docket 50-255 - License DPR Palisades Plant - Technical Spec1f1cat1on Change Request Revision - Control Room Habitab1lity,"

Consumers Power Company, February 28, 1986.

16. Kenneth W. Berry letter to D1rector, Nuclear Reactor Regulation, "Docket 50-255 - l1cense DPR Pal1sades Plant - Technical Specification Change Request - Core Exit Thermocouples," Consumers Power Company, November 21, 1985.

17. Thomas V. Wambach letter to Kenneth W. Berry, "Auxiliary Feedwater System - Technical Specifications," U.S. Nuclear Regulatory Comm1ss1on, January 30, 1986.

18. Denn\s M. Crutchfield letter to David J. VandeWalle, "NUREG-0737, Item 111.D.3.4, Control Room HabHab11Hy," U.S. Nuclear Regulatory Commission, April 29, 1983.

20

NAC FOAM 335 U.S. NUCLEAR AEGULATOAV COMMISSION 1. REPORT NUMBER IAu*gn<<I Ov TIOC. *dd Vol. No.. ii *nvJ 12*8*1 NRCM 1102.

J201, J202 BIBLIOGRAPHIC DATA SHEET EGG-NTA-7484 SEE INSTRUCTIONS ON THE REVERSE.

2. TITLE ANO SUBTITLE 3. LEAVE BLANK TECHNICAL EVALUATION REPORT FOR THE PALISADES PLANT RESPONSE TO NRR GENERIC LETTER 83-37

• OATE REPORT COMPLETED

5. AUTHORISI MONTH March I YEAR 1987 E. V. Mobley 6. DATE REPORT ISSUED MONTH March I YEAR 1987

7. PERFORMING ORGANIZATION NAME ANO MAILING AOORESS llnclu~ z,o Ctn*/ B. PROJECT/TASK/WORK UNIT NUMBER NRR and I&E Support EG&G Idaho, Inc. 9. FIN OR GRANT NUMBER P. 0. Box 1625 D6022 Idaho Fa 11 s, ID 83415

10. SPONSORING ORGANIZATION NAME ANO MAILING ADDRESS {lnclud* Zia Coo*/ 111. TYPE OF REPORT Division of Licensing Technical Evaluation Report Office of Nuclear Reactor Regulation o. PERICO COVEREO l/nclu1i** <UtesJ U.S. Nuclear Regulatory Commission Washington, DC 20555 12 SUPPLEMENTARY NOTES

13. ABSTRACT (200 words or !*111 Interim Technical evaluation report on the audit of the Palisades Plant Technical Specifications performed for the NRC in connection with conformance to the requirementsof the NRR Generic Letter No. 83-37, 11 NUREG'.""0737 Technic!3.l Specifications".

,.

1' DOCUMENT ANALYSIS - '* KEYWOROSIOESCRIPTDRS 15. AVAILABILITY STATEMENT Unlimited

16. SECURITY CLASSIFICATION fThi1 f>>ll*I

b. IDENTIFIERS/OPEN.ENDED TERMS Unclassified tr1ti1reoon1 Unclassified

17. NUMBER OF PAGES

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