ML18066A343
| ML18066A343 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/04/1998 |
| From: | Robert Schaaf NRC (Affiliation Not Assigned) |
| To: | Haskell N CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| TAC-MA0805, TAC-MA805, NUDOCS 9812100167 | |
| Download: ML18066A343 (13) | |
Text
Mr. Nathan L. Haskell Di'rector, Licensing PalisaC:fes Plant December 4, 1998 ~
27780 'slue Star Memorial Highway Covert, Ml 49043
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING THE TECHNICAL SPECIFICATIONS CHANGE REQUEST TO CONVERT TO THE IMPROVED TECHNICAL SPECIFICATIONS FOR THE PALISADES PLANT (TAC NO.
MA0805)
Dear Mr. Haskell:
On January 26, 1998, Consumers Energy submitted its request to convert the Palisades Nuclear Plant current technical specifications (CTS) to improved technical specifications {ITS).
We have determined that we require additional information to complete our evaluation of ITS
- Sections 2.0, 3.1, and 3.2. The enclosed request was discussed with Mr. B. Young of your staff on December 4, 1998, and a mutually agreeable completion schedule for your response of 60 days from the date of this letter was established. If you should have any questions regarding this request, please contact me at (301) 415-1312 or Mary Lynn Reardon of the Technical Specifications Branch at (301) 415-1177.
Docket No. 50-255
Enclosure:
As stated cc w/encl: See next page Distribution (w/encl):
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Mr. Nathan L. Haskell Director, Licensing Palisades Plant 27780 Blue Star Memorial Highway Covert, Ml 49043 December 4, 1998
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING THE TECHNICAL SPECIFICATIONS CHANGE REQUEST TO CONVERT TO THE IMPROVED TECHNICAL SPECIFICATIONS FOR THE PALISADES PLANT (TAC NO. -
MA0805)
Dear Mr. Haskell:
On January 26, 1998, Consumers Energy submitted its request to convert the Palisades Nuclear Plant current technical specifications (CTS) to improved technical specifications (ITS).
We have determined that we require additional information to complete our evaluation of ITS Sections 2.0, 3.1, and 3.2. The enclosed request was discussed with Mr. B. Young of your staff on December 4, 1998, and a mutually agreeable completion schedule for your response of 60 days from the date of this letter was established. If you should have any questions regarding this request, please contact me at (301) 415~1312 or Mary Lynn Reardon of the Technical Specifications Branch at (301) 415-1177.
Docket No. 50-255
Enclosure:
As stated cc w/encl: See next page Sincerely, Robert G. Schaaf, Project Mana er Project Directorate 111-1 Division of Reactor Projects - Ill/IV Office of Nuclear Reactor Regulation
Mr. Nathan L. Haskell Consumers Energy Compahy cc:
Mr. Thomas J. Palmisano Site Vice President Palisades Plant 27780 Blue Star Memorial Highway Covert, Michigan 49043 Mr. Robert A. Fenech, Sr Vice Pres Nuclear, Fossil, and Hydro Operations Consumers Energy Company 212 West Michigan Avenue Jackson, Michigan 49201 Arunas T. Udrys, Esquire Consumers Energy Company 212 West Michigan Avenue Jackson, Michigan 49201 Regional Administrator, Region Ill U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532-4351 Jerry Sarno, Supervisor Covert Township P. 0. Box35 Covert, Michigan 49043 Office of the Governor P. 0. Box 30013 Lansing, Michigan 48909
. U.S. Nuclear Regulatory Commission
. Resident Inspector's Office Palisades Plant 27782 Blue Star Memorial Highway Covert, Michigan 49043 Palisades Plant Drinking Water and Radiological Protection Division Michigan Department of Environmental Quality 3423 N. Martin Luther King Jr Blvd P. 0. Box 30630 CPH Mailroom Lansing, Michigan 48909-8130 Michigan Department of Attorney General Special Litigation Division 630 Law Building P.0; Box 30212 Lansing, Michigan 48909 August 1998
Palisades Improved TS Review Comments Section 2.0 Safety Limits 2.0-01 Safety Limits Applicability B SL 2.1.2 Applicability, Bases page B 2.1.2-3 JFD-7
- The STS SL 2.1.2 applicability has been expanded in ITS 2.1.2 to include Mode 6, in accordance with the CTS 2.2 applicability that includes "when there is fuel in the reactor."
- Comment: The ITS Bases, B SL 2.1.2, Applicability addressing Mode 6 is not stated in a logical way; "The.SL is applicable in MODE 6 because the... closure bolts are less than fully tensioned, making it possible that the PCS can be pressurized." Suggest that the bases be more clearly written; i.e., "When the closure bolts are less than fully tensioned the SL is applicable because it is possible... n.
CE Response:
ENCLOSURE
3.1-01 Palisades Improved TS Review Comments Section 3.1 Reactivity Control Systems ITS 3.1.1 Shutdown Margin (SOM)
LCO 3.1.1, SR 3.1.1.1 and SR 3.1.1.2 DOC A.6 and DOC M.2 JFD 7 and JFD 9 ITS LCO 3.1.1 states that "SOM shall be within limits," without referring to a COLR or explicitly stating the SOM limits. The ITS 3.1.1 limits and their applicability are defined in SR 3.1.1.1 and SR 3.1.1.2. TSTF-9 revised the STS from having the limits explicitly stated in the LCO to referencing the COLR in the LCO.
Comment: The ITS uses an unacceptable and cumbersome method to define LCO limits.
Recommend either including the limits in the LCO, thereby enabling the use of only one SR, or utilizing the COLR as is done with other specifications.
CE Response:
3.1-02 ITS 3.1.3 [STS 3.1.4] Moderator Temperature Coefficient (MTC)
ITS SR 3.1.3.1 and STS SR 3.1.4.1 Note JFD 11 The STS SR 3.1.4.1 includes a note that the SR need not be performed prior to entry into Mode 2. This note has been excluded in the ITS because the frequency specifies prior to 2% RTP.
Comment: The SR frequency does not negate the applicability of SR 3.0.4; that SRs must be met prior to entry into modes of applicability. In any case, including the note avoids misinterpretation. Recommend including the note.
CE Response:
3.1-03 ITS 3.1.3 [STS 3.1.4] Moderator Temperature Coefficient (MTC)
STS SR 3.1.4.2 JFD6 The STS SR 4.1.4.2 is not included because it is not in the CTS and "... the most negative limit is also assured of being met by design."
Comment: Once the initial MTC measurement is met is it always true that end-of -cycle (EOC) measurements will be met for all core loadings? Is this a plant unique feature?
CE Response:
2
3.1-04 Palisades Improved TS Review Comments Section 3.1 Reactivity Control Systems ITS 3.1.4 [STS 3.1.5] Control Rod Alignment ITS 3.1.4 Required Action D Bases LCO section (page B 3.1-26) and Bases ACTIONS (page B 3.1-30)
DOC M.6 JFD 10 and JFD 17 The ITS has added a Required Action D that an immovable but trippable control rod shall be returned to operable status prior to entering Mode 2.
Comments: (1) The completion time for the Required Action is prior to entering the LCO's applicability, which is illogical; the condition is not needed. (2) The definition for operable control rod is at variance with the STS definition. In the STS control rod operability is equated with trippability, not movability. In the ITS the control rods must be trippable and movable to be operable; for plants converting to the STS this is a plant unique definition, why? Recommend deleting Required Action D. (3) The only element to Part Length Control Rod Operability is that they be fully withdrawn; they do not need to be either Trippable or Moveable.
CE Response:
3.1-05 ITS 3.1.4 [STS 3.1.5] Control Rod Alignment ITS 3.1.4 Required Actions A and B, Completion Times ITS SR 3.1.4.1 and SR 3.1.4.2 DOC A.4, DOC M.3 and JFD 19 The ITS adds new Required Actions to perform a rod position verification (SR 3.1.4.1) 15 minutes after control rod movement when either a channel of rod position indication is inoperable or when the rod position deviation alarm is inoperable.
Comments:. (1) The completion times should include a 15 minute requirement for when the inoperability is first discovered (i.e., "15 minutes AND Once within... "). (2) Discuss how a rod position verification and a channel check differ.
CE Response:
3
I L
3.1-06 Palisades Improved TS Review Comments Section 3.1 Reactivity Control Systems ITS 3.1.5 [STS 3.1.6] Shutdown and Part Length Rod Group Insertion Limits ITS 3.1.5 Applicability JFD 6 and DOC A.6 The ITS applicability differs from both the STS and CTS by equating control rods withdrawn less than 5 inches with fully inserted control rods.
Comment: During startup, are the Regulating Control Rods "bumped" off the bottom <5" before
- the Shutdown and Part Length Control Rods are fully withdrawn?
CE Response:
3.1-07 ITS 3.1.5 [STS 3.1.6] Shutdown and Part Length Rod Group Insertion Limits Bases ITS 3.1.5 LCO Section (page B 3.1-36) Insert 2 JFD8 The ITS 3.1.5 Bases LCO paragraph includes clarifying information provided as Insert 2.
Comment: This information adds clarity and conservatism. Request that a TSTF be provided to incorporate this information into the STS.
CE Response:
3.1-08 ITS 3.1.6 [STS 3.1.7] Regulating Rod Group Position Limits ITS 3.1.6 Required Action B, Completion Time ITS SR 3.1.6.1 DOC A.4 and JFD 5 The ITS adds a new Required Action to perform a rod position verification (SR 3.1.6.1) 15 minutes after control rod movement when either the PDIL Alarm Circuit or the GROOS Alarm Circuit are inoperable.
Comment: The completion times should include a 15 minute requirement for when the inoperability is first discovered (i.e., "15 minutes AND Once within... ").
CE Response:
4
3.1-09 Palisades Improved TS Review Comments Section 3.1 Reactivity Control Systems ITS 3.1.6 [STS 3.1. 7] Regulating Rod Group Position Limits ITS 3.1.6 LCO and Required Action B ITS SR 3.1.6.1 DOC M.1 and JFD 10 The ITS includes explicit sequence and overlap requirements in the LCO, Required Actions and in SR 3.1.6.1.
Comment: This information adds clarity and conservatism. Request that a TSTF be provided to incorporate this information into the STS.
CE Response:
3.1-10 ITS 3.1.6 [STS 3.1.7] Regulating Rod Group Position Limits Bases ITS 3.1.6 LCO Section (page B 3.1-42) Insert 2 JFD 13 The ITS 3.1.6 Bases LCO paragraph includes clarifying information provided as Insert 2.
Comment: This information adds clarity and conservatism. Request that a TSTF be provided to incorporate this information into the STS.
CE Response:
. 3.1-11 ITS 3.1.7 [STS 3.1.9] Special Test Exception ITS 3.1. 7 LCO Requirements JFD 17 The ITS changes the STS SOM requirement to *~1% shutdown reactivity... ".
Comment: What is the value of "1 %shutdown reactivity" based upon?
CE Response:
5
3.1-12 Palisades Improved TS Review Comments Section 3.1 Reactivity Control Systems ITS 3.1. 7 [STS 3. 1. 9] Special Test Exception ITS 3.1. 7 Required Actions B and D JFD 14 and JFD 15 The ITS revises the STS Required Actions making them more logical.
Comment: This information adds clarity. Request that a TSTF be provided to incorporate this information into the STS.
CE Response:
6
3.2-01 Palisades Improved TS Review Comments Section 3.2 Power Distribution Limits ITS 3.2.1 Linear Heat Rate (LHR)
ITS 3.2.1 LCO JFD 8 The ITS 3.2.1 LCO adds, "as determined by an OPERABLE lncore Alarm System or by an OPERABLE Excore Monitoring System," which is neither in the CTS nor the STS.
Comment: The wording of the LCO precludes the Condition A option of "OR LHR, as determined by manual incore readings, not within limits...". Suggest that the LCO be reworded to add the straight forward requirement that the lncore Alarm System and the Excore Monitoring System shall both be operable.
CE Response:
3.2-02 ITS 3.2.1 Linear Heat Rate (LHR)
ITS 3.2.1 Surveillance Requirements JFD 9 The STS SRs have been changed in the ITS to be consistent with the CTS.
Comments: (1) The ITS SR 3.2.1.1 Note incorrectly references LCO 3.2.5 and LCO 3.2.6.
What is the purpose of this note? Recommend deleting note. (2) Provide ITS SR 3.2.1.1 an appropriate specific frequency. (3) ITS SR 3.2.1.3 and ITS SR 3.2.1.5 should appear with the ASI specification; recommend moving to ITS 3.2.4. (4) ITS SR 3.2.1.6 should appear with the Tq specification; recommend moving to ITS 3.2.3.
CE Response:
3.2-03 ITS 3.2.1 Linear Heat Rate (LHR)
ITS SR 3.2.1.2 Frequency JFD 10 The frequency for ITS SR 3.2.1.2 has been changed, from 7 days in the CTS and 31 days in the STS, to 31 EFPD; a beyond scope change.
Comment: Recommend retaining the STS frequency of 31 days for ITS SR 3.2.1.2.
CE Response:
7
3.2-04 Palisades Improved TS Review Comments Section 3.2 Power Distribution Limits ITS 3.2.2 Radial Peaking Factors ITS 3.2.2 Required Action B DOC M.1, JFD 5 and JFD 8 The CTS requires going to Hot Shutdown (similar to Mode 3) in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> if peaking factors are not within limits, with Power <50% RTP. The ITS requires going to~25% RTP in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> if peaking factors are not returned to within limits in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Comments: (1) In the STS, when a radial peaking factor is not within limit the first action is to reduce power. The ITS allows 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> delay prior to reducing power. The ITS should more closely reflect the STS actions. (2) This change to the CTS is less restrictive and needs to be appropriately justified.
CE Response:
3.2-05 ITS 3.2.2 Radial Peaking Factors ITS SR 3.2.2.1 Frequen.cy DOC L.2 and JFD 9 The frequency for ITS SR 3.2.2.1 has been changed, from 7 days in the CTS and 31 days in the STS, to 31 EFPD; a beyond scope change.
Comment: Recommend retaining the STS frequency of 31 days for ITS SR 3.2.2.1.
CE Response:
3.2-06 ITS 3.2.3 [STS 3.2.4] Power Tilt (Tq)
ITS 3.2.3 [STS 3.2.4] LCO and Required Actions JFD 1 and JFD 5 STS 3.2.4 has been rewritten to reflect CTS limits in ITS 3.2.3.
Comments: (1) The ITS has not retained STS Required Action C.3 to restore Tq to <[0.03] prior to increasing thermal power (if Tq is no longer >[0.1 O]); submit TSTF for change to STS. NRC to review. (2) The ITS has not retained the STS Notes to the Required Action C and the related Completion Times, though similar requirements are retained in administrative controls; submit TSTF for change to STS. NRC to review.
CE Response:
8
3.2-07 Palisades Improved TS Review Comments Section 3.2 Power Distribution Limits ITS 3.2.3 [STS 3.2.4) Power Tilt (Tq)
ITS 3.2.3 [STS 3.2.4] Bases to Required Actions (STS pages B 3.2-23 & B 3.2-24)
JFDS The STS Bases contains two paragraphs addressing STS Required Actions C.1, C.2 and C.3, that have been deleted in the ITS Bases.
Comment: Recommend retaining this information tailored for Palisades.
CE Response:
3.2-08 ITS 3.2.3 [STS 3.2.4) Power Tilt (Tq)
ITS 3.2.3 [STS 3.2.4) Required Actions DOC L.1 and DOC M.3 The CTS required action if Tq is >0.15 is to go to Hot Shutdown in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while the ITS required action is to decrease power to ~25% RTP in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
Comment: Confirm that the ITS Applicability is appropriate and that the CTS required action is overly restrictive. When Tq becomes too large shutting down may be the appropriate action.
CE Response:
3.2-09 ITS 3.2.3 [STS 3.2.4] Power Tilt (Tq)
ITS SR 3.2.1.6 CTS SR4.19.1.1.b Proposed ITS SR 3.2.1.6 (CTS SR 4.19.1.1.b) imposes a limit on Tq of 0.03.
Comment: This limit does not appear anywhere in any ITS LCO limit; why not? Should the STS limits be adopted?
CE Response:
9
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3.2-10 Palisades Improved TS Review Comments Section 3.2 Power Distribution Limits ITS 3.2.3 [STS 3.2.4] Power Tilt (Tq)
ITS 3.2.3 Required Action C DOC M.2 ITS Condition C (default actions if required action not met) is an addition to CTS actions.
Comment: Wouldn't the CTS actions implicitly required a similar action? How is this more restrictive; is this an administrative change?
CE Response:
10